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WENTWORTH v. COMMISSIONER

Docket No. 3913-71.

32 T.C.M. 925 (1973)

T.C. Memo. 1973-199

Theodore O. Wentworth and Shirley M. Wentworth v. Commissioner.

United States Tax Court.

Filed September 10, 1973.

Attorney(s) appearing for the Case

Bart A. Brown, Jr., J. Neal Gardner, and Conrad Magrish, for the petitioners. Juandell D. Glass, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies in petitioners' income tax as follows:

  Year                        Deficiences

  1964 .....................  $145,695.49
  1965 .....................   115,385.00
  1966 .....................     2,523.00

Certain concessions have been made by both parties.

The questions remaining for decision are: (1) Whether withdrawals...

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