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GERSTELL v. COMMISSIONER

Docket No. 63085.

21 T.C.M. 994 (1962)

T.C. Memo. 1962-181

Robert S. Gerstell and Alice R. Gerstell v. Commissioner.

United States Tax Court.

Filed July 30, 1962.

Attorney(s) appearing for the Case

Richard H. Appert, Esq., 14 Wall St., New York, N. Y., and David Sachs, Esq., for the petitioners. William F. Fallon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent has determined deficiencies in income tax against petitioners as follows:

  Year                   Deficiency

  1952...............    $57,449.10
  1953...............     78,845.50
  1954...............     92,187.96

Petitioners claim a refund of $5,623.62 for 1952 and a refund is claimed in the alternative for the year 1954 in the amount of $14,386.23.

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