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S. GARBER, INC. v. COMMISSIONER

Docket No. 865-66.

51 T.C. 733 (1969)

S. GARBER, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 6, 1969.

Attorney(s) appearing for the Case

Maurice P. Raizes, for the petitioner.

William J. Gerard, for the respondent.

MULRONEY, Judge:

Respondent determined a deficiency in the petitioner's income tax for the taxable year ended January 31, 1963, in the amount of $7,659.91.

The issues for decision are (1) whether advance payments received by petitioner from its customers on fur garments to be custom-made are includable in petitioner's income in the year of receipt and, if so, (2) whether deduction should be allowable to petitioner...

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