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SEARS OIL CO., INC. v. COMMISSIONER

Docket No. 374-63.

24 T.C.M. 207 (1965)

T.C. Memo. 1965-39

Sears Oil Co., Inc. v. Commissioner.

United States Tax Court.

Filed February 25, 1965.

Attorney(s) appearing for the Case

Richard O'C. Kehoe, 516 Mayro Bldg., Utica, N. Y., for the petitioners. Stephen M. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The Commissioner has determined deficiencies in the income taxes of petitioner for the taxable years 1957 and 1958 in the respective amounts of $60,637.40 and $51,560.74.

The issues to be decided are (1) whether petitioner was availed of for the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation...

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