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DONNELLY v. COMMISSIONER

Docket No. 7615-72.

33 T.C.M. 1002 (1974)

T.C. Memo. 1974-226

Simon J. Donnelly and Katherine Donnelly v. Commissioner.

United States Tax Court.

Filed August 29, 1974.

Attorney(s) appearing for the Case

Sidney Meyers, 51 Chambers St., New York, N.Y., for the petitioners. L. William Fishman, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent has determined deficiencies in the income tax of petitioners for the taxable years 1967 and 1968 in the amounts of $8,921.02 and $8,337.33, respectively.

The only questions before the Court for our determination are as follows:

(1) Whether petitioner Simon J. Donnelly is entitled to deduct under section 1621

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