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RESNICK v. COMMISSIONER

Docket No. 575-72.

63 T.C. 524 (1975)

ANN B. RESNICK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 3, 1975.

Attorney(s) appearing for the Case

Gordon D. Simonds, for the petitioner.

Donald W. Williamson, Jr., for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency of $2,851,879.75 in petitioner's Federal income tax for 1968 and an addition to tax under section 6653(b)1 in the amount of $1,425,939.88.2

The only issue for decision is whether section 6013(e) is applicable to relieve petitioner from liability for tax where the liability results from a decrease in cost of goods sold rather...

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