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NEWSOM v. COMMISSIONER

Docket No. 32810.

22 T.C. 225 (1954)

E. C. NEWSOM AND BEATRICE D. NEWSOM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1954.

Attorney(s) appearing for the Case

James P. Hill, Esq., and William R. Frazier, Esq., for the petitioners.

Stanley Schoenbaum, Esq., for the respondent.

OPINION.

OPPER, Judge:

Respondent determined a "deficiency of penalty" of $1,627.92 for the year 1948 against petitioners for substantial understatement of estimated income tax under section 294 (d) (2) of the Internal Revenue Code. There was no other "deficiency" determined in the statutory notice. Petitioners moved to dismiss their own petition on the ground that the Tax Court has no jurisdiction to consider...

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