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WOLFSON v. COMMISSIONER

Docket No. 7711-74.

37 T.C.M. 1847 (1978)

T.C. Memo. 1978-445

William Q. Wolfson and Elizabeth Wolfson v. Commissioner.

United States Tax Court.

Filed November 7, 1978. Appealable, barring stipulation to the contrary, to CA-6. — CCH.

Attorney(s) appearing for the Case

Allan Adelson, 26211 Central Pk. Blvd., Southfield, Mich., for the petitioners. Thomas R. Ascher, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' income tax and additions to the tax for the calendar years as follows:

                                  Addition to Tax
  Year               Deficiency     Sec. 6651(a)

  1968 ............. $56,981.62      $5,665.68
  1969 .............   4,596.94
  1970 .............   6,827.03

Concessions having been made, the following...

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