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LICAVOLI v. COMMISSIONER

Docket Nos. 58055-58057.

15 T.C.M. 862 (1956)

Grace Licavoli v. Commissioner. Peter Licavoli v. Commissioner. Peter Licavoli and Grace Licavoli v. Commissioner.

United States Tax Court.

June 14, 1956.

Attorney(s) appearing for the Case

John F. Noonan, Esq., for the petitioners. John T. Rogers, Esq., for the respondent.

Memorandum to Accompany Order

MURDOCK, Judge:

The Commissioner, after deliberation, has refused to comply in these cases with orders of the Court that he set forth in greater detail in amended answers the facts upon which he relies to sustain his burden of proof on two fraud issues.

The Commissioner, in his deficiency notices, determined increases in the net income over that reported for each year but gave no

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