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TIBBALS v. COMMISSIONER

Docket No. 63527.

17 T.C.M. 228 (1958)

T.C. Memo. 1958-44

Charles E. Tibbals and Lillian Tibbals v. Commissioner.

United States Tax Court.

Filed March 19, 1958.

Attorney(s) appearing for the Case

Daniel A. Taylor, Esq., 135 South La Salle Street, Chicago, Ill., and Howard H. Baker, Jr., Esq., for the petitioners. David M. Robinson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves deficiencies in income tax of petitioners as follows:

  Year                   Deficiency        Section 294(d)(2)
                                           Additions to Tax
  1951 ..............     $   175.14        .........
  1952 ..............      29,663.56        $3,169.91
  1953 ..............      81,731.54         4,982.97

The issues are:

(1) Whether...

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