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C. F. SMITH COMPANY v. COMMISSIONER

Docket No. 32973.

13 T.C.M. 607 (1954)

T. C. Memo. 1954-86

C. F. Smith Company v. Commissioner.

United States Tax Court.

Filed June 30, 1954.

Attorney(s) appearing for the Case

C. C. Legerton, Esq., and V. Robert Antablin, Esq., for the petitioner. George E. Constable, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined deficiencies in income tax for the years 1947 and 1949, and he added to the tax for 1947 a 25 per cent penalty under section 291(a) of the Code as follows:

  Year                 Deficiency    Sec. 291(a)

  1947 ............    $1,167.79       $291.95
  1949 ............     1,963.05         None

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