MEDICAL COLLECTION CORPORATION v. COMMISSIONER

Docket Nos. 3652-75, 3653-75.

36 T.C.M. 1074 (1977)

T.C. Memo. 1977-266

Medical Collection Corporation v. Commissioner. Robert J. Smith v. Commissioner.

United States Tax Court.

Filed August 11, 1977.


Attorney(s) appearing for the Case

Edward S. Smith, Lawrence M. Katz, and Joseph H. Langhirt, for the petitioners. Robert K. Dowd, for the respondent.


Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' income taxes:

       Medical Collection Corporation

  Calendar Year             Deficiency

       1971 .........       $56,117.63
       1972 .........        72,055.17

               Robert J. Smith

  Calendar Year            Deficiency

       1971 .........      $ 3,760.68
       1972 ..........

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