SEMPLE v. COMMISSIONER

Docket Nos. 25780, 25781.

10 T.C.M. 795 (1951)

Donald B. Semple v. Commissioner. Vivian H. Semple v. Commissioner.

United States Tax Court.

Entered August 28, 1951.


Attorney(s) appearing for the Case

Donald B. Smith, Esq., E-1422 First Nat. Bank Bldg., St. Paul, Minn., for the petitioners. Thos. A. Steele, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined deficiencies in income tax and imposed penalties thereon for the calendar years 1945, 1946 and 1947, as follows:

            Income
    Year     Tax     Penalty

    1945   $275.00   $137.50
    1946    709.01    354.51
    1947    917.13    458.57

All of the above are based upon income earned and deductions claimed by petitioner, Donald B. Semple....

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