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ESTATE OF CAMPBELL v. COMMISSIONER

Docket No. 85391.

23 T.C.M. 398 (1964)

T.C. Memo. 1964-53

Estate of Ira A. Campbell, deceased, Donald Cameron and Lucian J. Clarke, executors and Estate of Zella Fay Campbell, deceased, Lucian J. Clarke, administrator, c. t. a. v. Commissioner.

United States Tax Court.

Filed March 2, 1964.

Attorney(s) appearing for the Case

Earl Q. Kullman, 120 Broadway, New York, N. Y., and Folger Brink, for the petitioners. Marie L. Garibaldi and Leo A. Burgoyne, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in income tax and additions to tax for the years 1950 and 1951 as follows:

                                     Additions
                                     to Tax Sec.
                                    294(d)(1)(A),
  Year                Deficiency  I. R. C. of 1939

  1950............    $11,992.51    $18,900.46
  1951............     31...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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