DOWNS v. COMMISSIONER

Docket Nos. 9643, 9644.

7 T.C. 1053 (1946)

MICHAEL DOWNS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ELEANOR J. DOWNS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 24, 1946.


Attorney(s) appearing for the Case

Robert A. Waring, Esq., for the petitioners.

A. J. Hurley, Esq., for the respondent.


The Commissioner has determined a deficiency of $225.79 for the year 1943 in income tax against Michael Downs, petitioner in Docket No. 9643, and he has determined against Eleanor J. Downs, wife of Michael and petitioner in Docket No. 9644, a deficiency for the same year of $219.52, plus delinquency penalty of 25 per cent, amounting to $54.88. In the deficiency notice addressed to petitioner Michael Downs it was stated:

Taxpayer has not established that...

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