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BERNARD v. COMMISSIONER

Docket No. 84863.

21 T.C.M. 613 (1962)

T.C. Memo. 1962-116

George Emil Bernard and Betty Bernard v. Commissioner.

United States Tax Court.

Filed May 16, 1962.

Attorney(s) appearing for the Case

Leonard Bailin, Esq., 1472 Broadway, New York, N. Y., for the petitioners. Arthur S. O'Neill, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MURDOCK, Judge:

The Commissioner determined a deficiency of $1,961.67 and an addition of $980.84 for fraud, in the income tax of the petitioners for 1957. He conceded at the trial that there was no fraud but alleged negligence. The issues for decision are

1. The amount of tips received by George;

2. Whether the petitioners furnished more than one-half of the support of a niece, and

3. Whether...

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