APTITUDE ASSOCIATES, INCORPORATED v. COMMISSIONER

Docket No. 92447.

21 T.C.M. 1485 (1962)

T.C. Memo. 1962-281

Aptitude Associates, Incorporated v. Commissioner.

United States Tax Court.

Filed November 28, 1962.


Attorney(s) appearing for the Case

William J. Morgan (an officer), Dunn Loring Rd., Merrifield, Va., for the petitioner. W. Dean Short, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined deficiencies against petitioner in income tax and additions to tax under section 6651(a) of the Internal Revenue Code of 1954 for the years and in amounts as follows:

  Year        Deficiency    Addition to tax

  1957 ....   $4,578.74       $228.94
  1958 ....      834.69         41.73

The issues presented for our decision are: (1) Whether the petitioner, an accrual basis taxpayer...

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