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BOWEN v. COMMISSIONER

Docket No. 23128.

13 T.C.M. 640 (1954)

T. C. Memo. 1954-92

Marion I. Bowen, also known as M. I. Bowen v. Commissioner.

United States Tax Court.

Filed June 30, 1954.

Attorney(s) appearing for the Case

Robert E. Forney, Esq., and W. J. Forney, C. P. A., for the petitioner. Stanley Schoenbaum, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income tax and penalties against petitioner as follows:

                                    Fraud    Negligence
  Year               Income Tax    Penalty     Penalty

  1943 ..........    $10,337.51      ......    $516.88
  1945 ..........     16,463.19    $6,880.46    ......

In his answer to the petition, respondent affirmatively alleged...

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