STOUMEN v. COMMISSIONER

Docket No. 26431.

12 T.C.M. 267 (1953)

Bernard Stoumen v. Commissioner.

United States Tax Court.

March 13, 1953.


Attorney(s) appearing for the Case

Morris Wolf, Esq., Morris H. Goldman, Esq., 12th Floor, Packard Building, Philadelphia, Pa., and Wesley H. Caldwell, Esq., for the petitioner. Jules I. Whitman, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves deficiencies in income tax and penalties as follows:

  Year                 Deficiency    50% Penalty

  1943 .............   $60,154.96    $30,077.48
  1944 .............    68,594.32     34,297.16
  1945 .............    51,700.99     25,850.50

The issues are whether respondent erred (a) in increasing the amount of petitioner's share of the profits...

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