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WILLIAMS v. COMMISSIONER

Docket Nos. 90538, 90539.

21 T.C.M. 1413 (1962)

T.C. Memo. 1962-265

Charles Dennis Williams v. Commissioner. Delbert R. Williams and Mildred Williams v. Commissioner.

United States Tax Court.

Filed November 15, 1962.

Attorney(s) appearing for the Case

Dean M. Alexander, Esq., 814 Executive Bldg., Portland, Ore., for the petitioners. William J. Luff, Jr., Esq., and John D. Picco, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

The Commissioner determined deficiencies in the petitioners' income taxes for 1955 of $8,033.76 at Docket No. 90538 and $5,473.27 at Docket No. 90539.

The only issue for decision is whether the petitioners may exclude from income in the taxable year 1955 the amount added to a dealer reserve, or, in the alternative, claim a deduction of the amount added to the reserve as a reasonable addition to...

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