Pyle v. Commissioner

Byron H. Pyle and Ruth Kennedy Pyle v. Commissioner.

Pyle v. Commissioner

Docket No. 91567.

United States Tax Court

T.C. Memo 1964-94; 1964 Tax Ct. Memo LEXIS 242; 23 T.C.M. (CCH) 568; T.C.M. (RIA) 64094;

April 13, 1964

Edward A. Fogel and Isaac Gluckman, for the petitioners. Lee Kamp and John B. Murray, for the respondent.

WITHEY

Memorandum Findings of Fact and Opinion

WITHEY, Judge: The respondent has determined deficiencies of $195,908.68 and $38,712.36 in the income tax of the petitioners for 1955 and 1957, respectively. The issues for determination are the correctness of the respondent's action:…