CASTELLS v. COMMISSIONER

Docket No. 74008.

20 T.C.M. 1442 (1961)

T.C. Memo. 1961-275

Alfonso Castells and Aurelia Castells v. Commissioner.

United States Tax Court.

Filed September 29, 1961.


Attorney(s) appearing for the Case

Cornelius Sacco, Esq., 551 Fifth Ave., New York, N. Y., for the petitioners. Warren S. Shine, Esq., and Herbert Rothenberg, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

Deficiencies in income tax and additions to tax were determined against petitioners as follows:

                            Additions to Tax
                     --------------------------------
                        Sec.     Sec. 294   Sec. 294
                       6653(b)   (d)(1)(A)   (d)(2)
                       I. R. C.   I. R. C.  I. R. C.
Year      Deficiency    1954     ...

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