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KLEINMAN v. COMMISSIONER

Docket Nos. 88709-88711.

22 T.C.M. 727 (1963)

T.C. Memo. 1963-153

George Kleinman, et al. v. Commissioner.

United States Tax Court.

Filed June 4, 1963.

Attorney(s) appearing for the Case

Morris K. Siegel, and Morris M. Silverman, 10 E. 40th St., New York, N. Y., for the petitioners. Joseph F. Rogers, and Eugene Parker, for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

In these consolidated cases the respondent determined deficiencies in the income tax of petitioners and additions to tax under section 293(b), Internal Revenue Code of 1939, for fraud, under section 294(d)(1)(A) for failure to file declaration of estimated tax, and under section 294 (d)(2) for substantial underestimate, as follows:

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