BATT v. COMMISSIONER

Docket No. 4919-62.

24 T.C.M. 565 (1965)

T.C. Memo. 1965-104

Warren R. Batt, Sr. and Optat M. Batt v. Commissioner.

United States Tax Court.

Filed April 20, 1965.


Attorney(s) appearing for the Case

Norman W. Prendergast, Maison Blanche Bldg., New Orleans, La., for the petitioners. Max B. Silverberg, for the respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

The respondent determined deficiencies in income tax for the calendar years 1959 and 1960 and additions to tax under section 6653(a) of the Internal Revenue Code of 1954 for negligence or intentional disregard of rules and regulations, in the following amounts:

                            Additions to Tax
                              Sec. 6653(a)
  Year          Deficiency    I. R. C. 1954...

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