DOYING v. COMMISSIONER

Docket No. 93283.

22 T.C.M. 462 (1963)

T.C. Memo. 1963-96

John C. and Xochitl G. Doying v. Commissioner.

United States Tax Court.

Filed April 3, 1963.


Attorney(s) appearing for the Case

Dale C. Campbell, Esq., for the petitioners. Ralph A. Anderskow, Esq., for the respondent.


Memorandum Opinion

DAWSON, Judge:

A deficiency in the income tax of petitioners for the taxable year 1957 has been determined by respondent in the amount of $438.26.

The issues for decision are:

(1) Whether respondent is barred in this action by failing to give notice in writing that a re-examination of petitioners' books was necessary pursuant to section 7605(b) of the 1954 Code.

(2) Whether petitioners are entitled to increase their...

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