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CONTI v. COMMISSIONER

Docket No. 3449-69.

31 T.C.M. 348 (1972)

T.C. Memo. 1972-89

Elmer W. Conti and June L. Conti v. Commissioner.

United States Tax Court.

Filed April 19, 1972.

Attorney(s) appearing for the Case

James E. Brown, 100 W. Monroe, Chicago, Ill., for the petitioners. Nelson E. Shafer, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' income tax and petitioners claim overpayments herein, as follows:

            1962                           1963

               Over-payment                  Over-payment
  Deficiency     claimed         Deficiency     claimed

  $195,727.46   $86,718.05       $4,799.48     $6,855.67

Several concessions having been...

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