CLEMENS v. COMMISSIONER

Docket No. 496-67.

28 T.C.M. 1225 (1969)

T.C. Memo. 1969-235

Arthur B. Clemens and Eleanor L. Clemens v. Commissioner.

United States Tax Court.

Filed November 4, 1969.


Attorney(s) appearing for the Case

Ardy V. Barton, 922 State, Santa Barbara, Calif., for the petitioners. Richard G. Daly, for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in petitioners' income tax, and additions to the tax, as follows:

                               Additions to Tax,
                                  I. R. C. 1954
 Taxable                        Sec.         Sec.
  Year              Tax        6651(a)      6653(a)

  1961 ......    $ 2,928.43   $  732.10      ...
  1962 ......     26,396.83    5,210.73   $1,319.84...

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