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GERARDO v. COMMISSIONER

Docket No. 7035-72.

34 T.C.M. 1480 (1975)

T.C. Memo. 1975-341

Andrew Gerardo v. Commissioner.

United States Tax Court.

Filed November 13, 1975.

Attorney(s) appearing for the Case

Edwin Fradkin and Harvey R. Zeller, 744 Broad St., Newark, N.J., for the petitioner. Robert N. Ginsburg, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in the Federal income tax of petitioner and additions to tax as follows:

                           Addition to Tax
  Year        Deficiency    Sec. 6653(b)1

  1966 ...... $807,386.80    $403,693.40
  1967 ......   91,862.83      45,931.41

We must decide whether petitioner failed to report, on the Federal income...

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