ERNST v. COMMISSIONER

Docket No. 6026-73.

34 T.C.M. 942 (1975)

T.C. Memo. 1975-217

Philip A. Ernst v. Commissioner.

United States Tax Court.

Filed June 30, 1975.


Attorney(s) appearing for the Case

Ira Kass, 2544 Towne House Circle, North Bellmore, N.Y., for the petitioner. Peter Matwiczyk, for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency in petitioner's income tax for 1966 and an addition to tax under section 6651(a), I.R.C. 1954, in the amounts of $8,094.87 and $2,023.71, respectively.

The notice of deficiency issued to petitioner was dated March 26, 1973. In his petition, petitioner raised the statute of limitations as a bar to the assessment and collection of the deficiency. In his answer...

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