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ESTATE OF SIMMONS v. COMMISSIONER

Docket No. 42726.

26 T.C. 409 (1956)

ESTATE OF HELENE SIMMONS, DECEASED, FIRST NATIONAL BANK IN HOUSTON, TEMPORARY ADMINISTRATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 31, 1956.

Attorney(s) appearing for the Case

Charles W. Bell, Esq., Clarence E. Kendall, Esq., and Clyde L. Wilson, Jr., Esq., for the petitioner.

Richard W. Janes, Esq., and Godfrey L. Munter, Jr., Esq., for the respondent.

The Commissioner determined that petitioner was liable for deficiencies in its decedent's income taxes, and for additions thereto for fraud as follows:

                                                Addition
Year                               Deficiency   for fraud

1946 ---------------------------   $38,762.87   $19,381.43
1947 ---------------------------    54,859.10    27,429.55

In the statement attached to the deficiency...

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