SHIBLEY v. COMMISSIONER

Docket No. 5094-69.

30 T.C.M. 597 (1971)

T.C. Memo. 1971-139

Peter R. and Joan B. Shibley v. Commissioner.

United States Tax Court.

Filed June 15, 1971.


Attorney(s) appearing for the Case

Lyman T. Burgess, for the petitioners. Joel Gerber, for the respondent.


Memorandum Findings of Fact and Opinion

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

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

  1965 ......  $ 2,013.94      $100.69
  1966 ......   13,697.44       684.87

The principal issue is whether two apartment houses owned by petitioner Peter R. Shibley...

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