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NICATH REALTY COMPANY, INC. v. COMMISSIONER

Docket Nos. 2305-64, 2306-64.

25 T.C.M. 1260 (1966)

T.C. Memo. 1966-246

Nicath Realty Company, Inc. v. Commissioner. Nicholas Hummel and Catherine Hummel v. Commissioner.

United States Tax Court.

Filed October 31, 1966.

Attorney(s) appearing for the Case

Theodore Tenny, Com. Bldg., Kansas City, Mo., for the petitioners. Donald W. Geerhart, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Some of the facts have been stipulated and are so found. Nicholas and Catherine Hummel, the petitioners in Docket No. 2306-64, are husband and wife. They filed joint Federal income tax returns for the years in question with the district director of internal revenue at Kansas City, Missouri. The respondent determined deficiencies in their returns as follows:

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