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LOEB v. COMMISSIONER

Docket No. 21935.

10 T.C.M. 165 (1951)

Alvin S. Loeb v. Commissioner.

United States Tax Court.

Entered February 20, 1951.

Attorney(s) appearing for the Case

Thomas I. Sheridan, Esq., for the petitioner. John J. Madden, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioner's income tax of $117,323.21 for the year 1943 and fraud penalty of $58,661.61. The deficiency notice does not give any details as to separate items of income upon which the deficiency is based. A statement attached to the deficiency notice states:

"Your income tax liability has been determined in accordance with a report of an examination, a copy of which...

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