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MARCELLE v. COMMISSIONER

Docket No. 52966.

15 T.C.M. 1174 (1956)

T.C. Memo. 1956-223

Joseph P. Marcelle and Anna Rose Marcelle v. Commissioner.

United States Tax Court.

Filed September 28, 1956.

Attorney(s) appearing for the Case

Anthony A. Marcelle, Esq., 15 Park Row, New York, N. Y., Albert I. Schmalholz, Esq., and Samuel Bader, Esq., for the petitioners. William G. O'Neill, Esq., and Emil Sebetic, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in income tax and additions to income tax under section 293(a) of the Internal Revenue Code of 1939 for the calendar years 1948, 1949, and 1950 as follows:

  Year              Deficiency   Addition

  1948 .........    $7,664.96    $383.25
  1949 .........     6,664.36     333.22
  1950 .........     4,714.38     235.72

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