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PACKERS DEVELOPMENT CORPORATION v. COMMISSIONER

Docket No. 6137-64.

26 T.C.M. 932 (1967)

T.C. Memo. 1967-188

Packers Development Corporation v. Commissioner.

United States Tax Court.

Filed September 28, 1967.

Attorney(s) appearing for the Case

Gregory Gramling, Jr., 739 N. Broadway, Milwaukee, Wis., and William Fitzhugh Fox, for the petitioner. Robert M. Burns, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following income tax deficiencies against petitioner:

  Taxable year                 Deficiency

     1959..................    $3,140.76
     1960..................    7,857.55
     1961..................    6,111.45

There are two issues for decision: (1) Whether petitioner was a personal holding company...

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