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PATTERSON v. COMMISSIONER

Docket Nos. 4639-64, 4640-64.

25 T.C.M. 1230 (1966)

T.C. Memo. 1966-239

Floyd Patterson and Sandra Patterson v. Commissioner. Floyd Patterson Enterprises, Ltd. v. Commissioner.

United States Tax Court.

Filed October 26, 1966.

Attorney(s) appearing for the Case

Edwin Stephen Schweig and Julius November, 51 Chambers St., New York, N. Y., for the petitioners. Robert D. Whoriskey and Wallace Musoff, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in the income tax of Floyd and Sandra Patterson in the amounts of $17,436.57 for 1957 and $24,212.07 for 1958 and deficiencies in the income tax of Floyd Patterson Enterprises, Ltd. of $7,500.10 for the taxable year ended November 30, 1957 and $37,235.90 for the taxable year ended November 30, 1958.

After settlement of certain issues raised by the deficiency...

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