TODD v. COMMISSIONER

Docket No. 646-64.

25 T.C.M. 1099 (1966)

T.C. Memo. 1966-212

F. Payson and Mary K. Todd v. Commissioner.

United States Tax Court.

Filed September 28, 1966.


Attorney(s) appearing for the Case

F. Lee Bailey, for the petitioners. Frederick A. Griffen, for the respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in the income taxes of petitioners and additions to tax for the years and in the amounts as follows:

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

1955...............    $   422.42         $211.21
1956...............     39,876.82      ...

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