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LOWERY v. COMMISSIONER

Docket No. 69978.

39 T.C. 959 (1963)

SYLVESTER J. LOWERY AND ROSEMARY P. LOWERY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 21, 1963.

Attorney(s) appearing for the Case

Joseph F. McVeigh, Esq., for the petitioners.

Edward L. Newberger, Esq., for the respondent.

OPINION.

BRUCE, Judge:

The respondent determined deficiencies in income tax, and additions to tax under section 291 (a), I.R.C. 1939, for failure to file a timely return, and under section 294(d) (2) for substantial underestimate of tax, as follows:

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