STEWART v. COMMISSIONER

Docket No. 17786.

8 T.C.M. 1075 (1949)

Charles M. Stewart and Annie E. Stewart v. Commissioner.

United States Tax Court.

Entered December 19, 1949.


Attorney(s) appearing for the Case

B. A. Willcox, Esq., for the petitioners. Newman A. Townsend, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

This proceeding involves determinations of deficiencies in petitioners' income tax for 1944, 1945, and 1946. Fraud penalties are in issue for each of these years. The deficiencies and fraud penalties are as follows:

                                  50% Fraud
  Year                Deficiency   Penalty

  1944 .............  $  249.87   $  124.94
  1945 .............   1,463.63      731.82
  1946 ............

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