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SACHS v. COMMISSIONER

Docket Nos. 30216, 35508.

11 T.C.M. 882 (1952)

Mary Sachs v. Commissioner.

United States Tax Court.

Entered August 20, 1952.

Attorney(s) appearing for the Case

Herman H. Krekstein, Esq., 1528 Walnut St., Philadelphia, Pa., Manuel Kraus, Esq., and Barton E. Ferst, Esq., for the petitioner. Edward Pesin, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

LEMIRE, Judge:

These consolidated proceedings involve income tax deficiencies and penalty for the periods and in the amounts as follows:

  Year Ended 1-31    Income Tax    Penalty

  1944............    $47,652.77   $2,382.64
  1945............     20,758.97   .........
  1946............     20,548.59   .........

The issues are whether the respondent erred —

1. In disallowing...

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