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PARTICELLI v. COMMISSIONER

Docket Nos. 25439, 25440.

11 T.C.M. 150 (1952)

Giulio Particelli v. Commissioner. Estate of Eletta Particelli, Deceased, Arthur Guerrazzi, Executor v. Commissioner.

United States Tax Court.

Entered February 20, 1952.

Attorney(s) appearing for the Case

Valentine Brookes, Esq., for the petitioners. Leonard Allen Marcussen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These proceedings were consolidated for hearing. Each case involves a deficiency in income tax for the year 1943 in the amount of $62,222.85 arising from community income. Issues settled by stipulation will be reflected in the computation under Rule 50. The only remaining issue, which is common to both proceedings, is whether respondent erred in his allocation of community income derived from the sale of an inventory of wine...

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