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DEMIRJIAN v. C. I. R.

Nos. 19542, 19543.

457 F.2d 1 (1972)

Mihran DEMIRJIAN and Mabel Demirjian, Appellants, v. COMMISSIONER OF INTERNAL REVENUE. ESTATE of Anne DEMIRJIAN, Deceased, Frank Demirjian, Executor, and Frank Demirjian, Surviving Spouse, Appellants, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided March 7, 1972.

Attorney(s) appearing for the Case

Ralph Neibart, Newark, N. J., for appellants.

John A. Townsend, Dept. of Justice, Tax Div., Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Richard W. Perkins, Attys., Tax Div., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before VAN DUSEN and HUNTER, Circuit Judges, and LAYTON, District Judge.

OPINION OF THE COURT

VAN DUSEN, Circuit Judge.

The petitioning taxpayers, Anne and Mabel Dermirjian,1 have filed a timely petition for review of an adverse decision of the Tax Court2 affirming a finding of tax deficiencies for 19623 by the Commissioner of Internal Revenue. The tax deficiencies were based on the failure to report $54,835.00 in gain for the taxable year...

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