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UNION COMMERCE BANK v. COMMISSIONER

Docket No. 75094.

20 T.C.M. 1359 (1961)

T.C. Memo. 1961-260

The Union Commerce Bank and Subsidiaries, Union Properties, Inc., Parksafe, Inc., The Daisy Hill Company v. Commissioner.

United States Tax Court.

Filed September 15, 1961.

Attorney(s) appearing for the Case

Thomas V. Koykka, Esq., and Fred D. Kidder, Esq., for the petitioners. Clarence C. Roby, Esq., and Frank W. Hardy, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

The following deficiencies are in controversy:

  Year             Deficiency

  1953...........  $212,982.53
  1954...........    90,159.12
  1955...........   136,858.59

The only issues remaining for our determination are (1) whether petitioner used an excessive rate in computing depreciation deductions; (2) whether petitioner's participating interest in liquidating trust...

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