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KINNEY v. COMMISSIONER

Docket No. 67225.

17 T.C.M. 1039 (1958)

T.C. Memo. 1958-209

Joseph N. Kinney, Jr., and Helen C. Kinney v. Commissioner.

United States Tax Court.

Filed December 11, 1958.

Attorney(s) appearing for the Case

R. H. Sabel, Esq., 1018 Farmers Bank Building, Pittsburgh, Pa., for the petitioners. Leo A. Burgoyne, Esq., for the respondent.

Memorandum Opinion

WITHEY, Judge:

The respondent determined deficiencies in petitioners' income tax for the years and in the amounts as follows:

  Year                          Amount

  1954 .....................   $452.44
  1955 .....................    268.18

The sole issue presented for our determination is the correctness of the respondent's action in determining that payments made during 1954 and 1955 by petitioner Joseph...

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