MILLER v. COMMISSIONER

Docket No. 63322.

19 T.C.M. 475 (1960)

T.C. Memo. 1960-92

Herman J. Miller v. Commissioner.

United States Tax Court.

Filed May 9, 1960.


Attorney(s) appearing for the Case

G. D. Walker, Esq., P. O. Box 24, Jonesboro, Ark., Jacob Rabkin, Esq., Alvin D. Lurie, Esq., for petitioner. Douglas M. Moore, Esq., for respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in income tax and additions to tax of petitioner for the calendar years 1950 and 1951 as follows:

                                    Additions to Tax
  Calendar       Income Tax      Sec. 294   Sec. 294
    Year           Deficiency    (d)(1)(A)    (d)(2)

    1950......   $116,036.81    .........   .........
    1951......     23,284.65    $2,557.98...

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