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BARNEY v. COMMISSIONER

Docket No. 711-66.

26 T.C.M. 109 (1967)

T.C. Memo. 1967-17

L. P. Barney and Dora Barney v. Commissioner.

United States Tax Court.

Filed January 31, 1967.

Attorney(s) appearing for the Case

Michael J. Hughes, 11 Edwards St., Helena, Mont., and George T. Bennett, for the petitioners. Walter John Howard, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following income tax deficiencies against the petitioners:

  Year                    Deficiency

  1961 .................   $1,607.93
  1962 .................    1,202.64
  1963 .................    1,514.43

The two issues for decision are: (1) Whether gains realized by petitioners from the sales of...

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