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PRATER v. COMMISSIONER

Docket Nos. 18825, 35980.

12 T.C.M. 872 (1953)

William A. Prater v. Commissioner. William Alexander Prater, d/b/a Prater Chenilles v. Commissioner.

United States Tax Court.

Entered July 31, 1953.

Attorney(s) appearing for the Case

John A. Smith, Sr., Esq., Talbotton, Ga., for the petitioner. Ralph V. Bradbury, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve deficiencies in income tax and penalties, as follows:

  Docket    Taxable    Income         50%
    Nos.     Years       Tax        Penalty

  18825 .... 1944    $86,138.71    $43,069.36
  35980 .... 1945     70,714.00     38,111.86

The issues to be determined are: (1) whether there was an understatement of net taxable income on returns filed by petitioner...

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