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JAFFE v. COMMISSIONER

Docket Nos. 93284, 3645-64.

26 T.C.M. 1110 (1967)

T.C. Memo. 1967-223

Ben Jaffe and Elsie Jaffe v. Commissioner.

United States Tax Court.

Filed November 8, 1967.

Attorney(s) appearing for the Case

Benjamin M. Brodsky, Claude A. Roth, and Elliot I. Goodman, 111 W. Jackson Blvd., Chicago, Ill., for the petitioners. Charles B. Wolfe, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The respondent determined deficiencies in income taxes for 1957 and 1958, and 5 percent additions to the tax for negligence under section 6653(a), 1954 Code, as follows:

  Year               Deficiency     Sec. 6653(a)

  1957 ...........  $1,000,203.11    $50,010.16
  1958 ...........   1,293.421.57     64,671.08

Several of the determinations of the respondent for each year...

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