LINQUATA v. COMMISSIONER

Docket No. 31006.

11 T.C.M. 501 (1952)

Anthony Linquata v. Commissioner.

United States Tax Court.

Entered May 20, 1952.


Attorney(s) appearing for the Case

Harry Bergson, Esq., 209 Washington St., Boston, Mass., for the petitioner. William C. W. Haynes, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined deficiencies in income tax and 50 per cent penalties as follows:

  Year               Deficiency     50% Penalty

  1942...........    $15,932.77     $  7,966.39
  1943...........     39,087.49       19,543.75
  1944...........     28,143.12       14,071.56

The petition assigns as error the respondent's failure to allow deductions for the full amount of expenses of operating...

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