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INDUSTRIAL CREDIT CO., INC. v. COMMISSIONER

Docket No. 3909-65.

26 T.C.M. 377 (1967)

T.C. Memo. 1967-75

Industrial Credit Co., Inc. v. Commissioner.

United States Tax Court.

Filed April 11, 1967.

Attorney(s) appearing for the Case

Peter Meloy, 555 Fuller Ave., Helena, Mont., John R. Kline, and J. Patrick Giblin, for the petitioner. Walter John Howard, Jr., for respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following income tax deficiencies against the petitioner:

  Year                            Deficiency

  1960 .......................    $ 1,818.50
  1961 .......................     10,491.86
  1962 .......................      8,098.65

Petitioner has conceded that for each of the years 1960, 1961, and 1962 the dealer's reserve, the loan to Donald...

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