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KIVO v. COMMISSIONER

Docket No. 54192.

15 T.C.M. 1190 (1956)

T.C. Memo. 1956-227

John Kivo v. Commissioner.

United States Tax Court.

Filed September 28, 1956.

Attorney(s) appearing for the Case

Charles E. Scribner, Esq., 40 Wall Street, New York, N. Y., for the petitioner. Charles B. Markham, Esq., and Ellyne E. Strickland, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves the following deficiencies in income tax:

  Year               Deficiency

  1945 ..........    $16,527.99
  1946 ..........     19,688.55
  1947 ..........     16,908.92

The sole issue is whether petitioner's son was entitled to 25 per cent of the net profits of the partnership, John Kivo & Company, during its fiscal years ended September 30, 1945 and 1946 and for the...

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