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ESTATE OF SPERLING v. COMMISSIONER

Docket No. 88167.

22 T.C.M. 1301 (1963)

T.C. Memo. 1963-260

Estate of Lillian Virginia Sperling, Deceased, Warren Richard Sperling, Administrator v. Commissioner.

United States Tax Court.

Filed September 26, 1963.

Attorney(s) appearing for the Case

Morris Horowitz, 120 W. 42nd St., New York, N. Y., for the petitioner. Eugene L. Wilpon, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's income tax and additions thereto under sections 293(a) and 294(d)(1)(A)1 as follows:

                     Deficiency
                            Additions to tax
                                       Sec. 294
Year     Income tax    Sec. 293(a)     (d)(1)(A)

1951...  $ 5,579.04     $278.95        $ 638...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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