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  5. 13 T.C.M. 424 (1954)
 

ESTATE OF MIRABELLI v. COMMISSIONER

Docket Nos. 36916, 36917.

13 T.C.M. 424 (1954)

T. C. Memo. 1954-26

Estate of Emma Mirabelli, Christine Froise and Olga Mirabelli, Co-Administrators v. Commissioner. Estate of Michael A. Mirabelli, Christine Froise and Gloria Mirabelli, Co-Administrators v. Commissioner.

United States Tax Court.

Filed April 30, 1954.

Attorney(s) appearing for the Case

Martin M. Lore, Esq., for the petitioners. John J. Hopkins, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve the following income tax deficiencies and penalties:

  Docket
   No.     Year                Tax       50% Penalty

  36916    1944 .......    $ 18,522.12    $ 9,261.06
           1945 .......      44,973.18     22,486.59
  36917    1944 .......     108,913.38     60,652.83**
           1945 .......     131,145.70     80,475.80**

** Penalty computed on net income...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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