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KOBERNAT v. COMMISSIONER

Docket Nos. 4295-70, 4296-70.

31 T.C.M. 593 (1972)

T.C. Memo. 1972-132

Leonard J. Kobernat v. Commissioner. Josephine R. Kobernat v. Commissioner.

United States Tax Court.

Filed June 20, 1972.

Attorney(s) appearing for the Case

Leonard J. Kobernat and Josephine R. Kobernat, pro se, 1121 Wilshire Ave., San Antonio, Tex. Daniel A. Taylor, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in each petitioner's income tax as follows:

  Year            Deficiency

  1966 ........... $  665
  1967 ...........  1,147

The two issues for decision are: (1) whether commissions received by Leonard J. Kobernat (hereinafter "Leonard") on purchases and sales of securities for his personal account, his wife's account, and their joint...

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