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FENN v. COMMISSIONER

Docket No. 11113-77.

40 T.C.M. 559 (1980)

T.C. Memo. 1980-229

Russell Fenn, Jr. and Anna Fenn v. Commissioner.

United States Tax Court.

Filed June 30, 1980.

Attorney(s) appearing for the Case

Joseph G. Aronson, 60 Park Place, Newark, New Jersey, for the petitioners. Joseph F. Maselli, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Year               Deficiency

  1974 ............  $ 9,580.61
  1975 ............  $12,188.60

The sole issue for decision is whether the amounts paid during the years 1974 and 1975 to Fenn Service Center, Inc., and Russell Fenn III by Fenn and Sons, Inc., of which petitioner Russell Fenn...

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