GOTTLIEB v. COMMISSIONER

Memorandum Findings of Fact and Opinion

This proceeding involves deficiencies in income tax and penalties asserted against Allen Sanford Gottlieb (hereinafter referred to as the petitioner) as transferee of the assets of his father, Samuel J. Gottlieb, as follows:

  Calendar Year      Income Tax   50% Penalty

  1941 ............  $   903.07   $   451.54
  1942 ............    4,446.78     2,223.39
  1943* ...........   41,569.47    20,784.74
 ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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