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SILVER v. COMMISSIONER

Docket No. 2088-70.

31 T.C.M. 402 (1972)

T.C. Memo. 1972-102

William C. Silver, Jr. v. Commissioner.

United States Tax Court.

Filed May 2, 1972.

Attorney(s) appearing for the Case

Michael J. Kenny, 60 Wall St., New York, N.Y., for the petitioner. Curtis W. Berner, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

Respondent determined a deficiency in petitioner's income tax for the taxable year 1966 in the amount of $1,582.53 and for the same taxable year an addition to tax under the provisions of section 6651(a) of the Internal Revenue Code of 1954 in the amount of $399.66.

The issues to be decided are:

(1) Whether petitioner is entitled to deduct...

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