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ESTATE OF MARSACK v. COMMISSIONER

Docket No. 66967.

19 T.C.M. 398 (1960)

T.C. Memo. 1960-75

Estate of Sam Marsack, Deceased, Betty Marsack, Administratrix, and Betty Marsack v. Commissioner.

United States Tax Court.

Filed April 14, 1960.

Attorney(s) appearing for the Case

A. L. Skolnik, Esq., 710 North Plankinton Avenue, Milwaukee, Wis., for the petitioners. Delman H. Eure, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The respondent has determined deficiencies in the income tax of the petitioners for the year 1951 in the amount of $14,209.36 and for the year 1953 in the amount of $3,701.28. Petitioners have claimed an overpayment for the year 1951 in the amount of $1,544.52.

The sole issue for determination is whether the respondent has erred in valuing at $22,500 certain patent license agreements distributed...

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