MACRAE v. COMMISSIONER

Docket Nos. 61091, 67789.

34 T.C. 20 (1960)

GORDON MACRAE AND SHEILA MACRAE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ALBERT GORDON MACRAE AND SHEILA MACRAE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 12, 1960.


Attorney(s) appearing for the Case

Bernard Speisman, Esq., and Jerald S. Schutzbank, Esq., for the petitioners.

Mark Townsend, Esq., and Michael P. McLeod, Esq., for the respondent.


FORRESTER, Judge:

Respondent has determined deficiencies and an addition in the income tax of petitioners for the calendar years 1952 and 1953 as follows:

                                                      Addition
Year                                 Deficiency   Sec. 294 (d) (2)

1952 -----------------------------   $23,998.38        -----------
1953 -----------------------------   109,768.42          $6,172...

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