FIHE v. COMMISSIONER

Docket Nos. 52394, 52396.

15 T.C.M. 696 (1956)

T.C. Memo. 1956-139

Albert J. Fihe v. Commissioner. Albert J. Fihe and Elizabeth M. Fihe v. Commissioner.

United States Tax Court.

Filed June 12, 1956.


Attorney(s) appearing for the Case

Albert J. Fihe, Esq., 1671 Casale Road, Pacific Palisades, Calif., for the petitioners. Mark Townsend, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined the following deficiencies in income tax and additions to tax for negligence under Section 293(a):

                                      5% Addition
                                         to Tax
  Year                 Deficiency    for Negligence

  1946 ............    $9,515.06        $475.75
  1947 ............       397.40         533.78
  1948 ....

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