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OFFUTT v. COMMISSIONER

Docket Nos. 87006, 87007.

22 T.C.M. 589 (1963)

T.C. Memo. 1963-126

George W. Offutt, III, and Jane P. Offutt and Pimmit Development Corporation v. Commissioner.

United States Tax Court.

Filed May 8, 1963.

Attorney(s) appearing for the Case

James Mullen, Esq., 1001 E. Main St., Richmond, Va., LeRoy R. Cohen, Jr., Esq., Frederick T. Gray, Esq., and Frank A. Hardy, Esq., for the petitioners. W. Ralph Musgrove, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FISHER, Judge:

These proceedings involve income tax deficiencies for 1954, 1955 and 1956 and additions to tax for 1954, as follows:

                                                                          Addition to Tax,
                   Petitioner                       Year    Deficiency    Sec. 294(d)(1)(A)
----------------------------------------------------------------------------------------...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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