C. H. LEAVELL & COMPANY v. COMMISSIONER

Docket No. 5864-67.

53 T.C. 426 (1969)

C. H. LEAVELL & COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 23, 1969.


Attorney(s) appearing for the Case

Tad R. Smith, for the petitioner.

John D. Laflin, for the respondent.


FEATHERSTON, Judge:

Respondent determined deficiencies in petitioner's income tax for its taxable years ending March 31, 1963 and 1965, in the amounts of $116,723.43 and $699, respectively, and found an overassessment for the year ending March 31, 1964, in the amount of $3,569.55.

Certain issues have been settled; the issues presented for decision are:

(1) Whether a joint venture, of which petitioner...

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