SHADES RIDGE HOLDING COMPANY, INC. v. COMMISSIONER

Docket Nos. 84652, 84653, 94991, 4219-62.

23 T.C.M. 1665 (1964)

T.C. Memo. 1964-275

Shades Ridge Holding Company, Inc., Transferee, et al. v. Commissioner.

United States Tax Court.

Filed October 21, 1964.


Attorney(s) appearing for the Case

Winston B. McCall, for the petitioners. George W. Calvert, for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

In these consolidated proceedings, respondent determined the following deficiencies in income tax and additions thereto under section 6653(b)2 due from petitioners Sam and Katherine Fiorella:

  Dkt.         Taxable    Income     Section 6653(b)
  No.           Year        Tax       Addition to Tax
  84653.......  1956    $286,693.04    $143,346.52
  94991...

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