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PATRICK v. C. I. R.

No. 12821.

275 F.2d 437 (1960)

O'Donnell and Elizabeth M. PATRICK, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

March 9, 1960.

Attorney(s) appearing for the Case

Robert E. Nelson, Green Bay, Wis., Thomas H. Krise, Indianapolis, Ind., for petitioner.

Charles K. Rice, Asst. Atty. Gen., Tax Division, Joseph Kovner, Lee A. Jackson, Harry Baum, Rita E. Hauser, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before KNOCH and CASTLE, Circuit Judges, and JUERGENS, District Judge.

CASTLE, Circuit Judge.

The Tax Court of the United States determined deficiencies in income tax and an addition to tax of petitioners as follows:

                        Addition to tax under
  Year   Deficiencies  Sec. 294 (d) (2). IRC 1939
  -----------------------------------------------
  1953   $2,164.63              -------
  1954    3,529.64              $324.76

These deficiencies and additions to tax arise from the Tax Court's decision...

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