LITTLE v. COMMISSIONER

Docket Nos. 10332, 10333.

6 T.C.M. 1133 (1947)

Sherman F. Little v. Commissioner. Juanita Little v. Commissioner.

United States Tax Court.

Entered October 22, 1947.


Attorney(s) appearing for the Case

S. L. Mayo, Esq., 924 Kirby Bldg., Dallas 1, Tex., and J. Cleo Thompson, Esq., for the petitioners. Allen T. Akin, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

These proceedings were consolidated for hearing and disposition. In the 90-day letters mailed about nine months after the petitioners filed their returns and several weeks after the making of a jeopardy assessment, the respondent determined an income tax deficiency of $43,713.43 and a 50 per cent fraud penalty of $21,856.72 against each petitioner for the calendar year 1944. These deficiencies were determined on the basis...

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