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COLLINS v. COMMISSIONER

Docket No. 5841-72.

61 T.C. 693 (1974)

ROBERT F. COLLINS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 7, 1974.

Attorney(s) appearing for the Case

Jack E. Bratter and Bradley D. Marcus, for the petitioner.

Alan R. Herson, for the respondent.

The Commissioner determined a deficiency in petitioner's 1968 income tax in the amount of $5,219.1 Four issues are presented for decision. These are (1) whether the Commissioner conducted an "unnecessary" examination or investigation in respect of petitioner's tax liability for 1968 contrary to the provisions of section 7605 (b), I.R.C. 1954; (2) whether the Commissioner failed to comply with the Service's recognized procedure (set forth in Rev...

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