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STAHL v. COMMISSIONER

Docket No. 2145-64.

25 T.C.M. 505 (1966)

T.C. Memo. 1966-94

Stanley Stahl v. Commissioner.

United States Tax Court.

Filed May 5, 1966.

Attorney(s) appearing for the Case

Jerome Kamerman, 11 West 42nd St., New York, N. Y., for the petitioner. Charles M. Costenbader, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

The respondent determined a deficiency in the Federal income tax of the petitioner for the year 1955 in the amount of $134,027.54. The petitioner has not put in issue some of the adjustments made by the statutory notice, and the amount of the deficiency now in dispute is $128,265.77.

The sole issue for our decision is whether the Stahl Development Corporation was formed or availed of principally...

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