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JOHN DELL, INC. v. COMMISSIONER

Docket Nos. 2098-72, 2099-72.

35 T.C.M. 1618 (1976)

T.C. Memo. 1976-356

Joan Dell, Inc. v. Commissioner. Estate of Saul Field, Deceased, Arthur Field, et al., Executors, and Molly Field v. Commissioner.

United States Tax Court.

Filed November 24, 1976.

Attorney(s) appearing for the Case

Richard N. Tilton, Jules Ritholz, Boris Kostelanetz and Edward J. Daus, for the petitioners. Stanley J. Goldberg and Peter Matwiczyk, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions under section 6653(b), as follows:1

                      Joan Dell, Inc.

                                       Additions to
  Taxable Year                          Tax under
     Ended              Deficiencies   Sec. 6653(b)

  Aug. 31, 1963 .....    $17,501.77     $10...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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