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THE MOTEL COMPANY v. COMMISSIONER

Docket No. 88320.

22 T.C.M. 825 (1963)

T.C. Memo. 1963-174

The Motel Company v. Commissioner.

United States Tax Court.

Filed June 26, 1963.

Attorney(s) appearing for the Case

Monroe J. Winsten, 320 Broadway, New York, N. Y., for the petitioner. Douglas D. Robertson, for the respondent.

Memorandum Findings of Fact and Opinion

PIERCE, Judge:

The respendent determined deficiencies against petitioner in its income tax for years and in amounts as follows:

  Taxable year ended
       April 30             Deficiency

   1956 ..................   $ 5,153.86
   1957 ..................    17,528.27
   1958 ..................    10,180.85

The issues presented are:

1. Whether certain advances to petitioner by Harry...

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