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ESTATE OF ADAMS v. COMMISSIONER

Docket No. 2989-64.

26 T.C.M. 1098 (1967)

T.C. Memo. 1967-221

Estate of Louise K. Adams, Deceased, Charles E. Jordon, Executor v. Commissioner.

United States Tax Court.

Filed November 3, 1967.

Attorney(s) appearing for the Case

Hugh R. Dowling and John W. Mooers, 1824 Barnett Bank Bldg., Jacksonville, Fla., for the petitioner. Marshall H. Barkin, for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

Respondent determined deficiencies in income tax for the years and in the amounts as follows:

  1960 ...................   $ 5,564.81
  1961 ...................     6,542.19
  1962 ...................    36,660.39

The issues for determination are:

(1) Whether the determination of deficiencies for the years 1960 and 1961 was invalid because it resulted from an unauthorized...

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