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STEVENS v. COMMISSIONER

Docket No. 53934.

14 T.C.M. 1318 (1955)

T.C. Memo. 1955-333

Edward Stevens and Leona Stevens v. Commissioner.

United States Tax Court.

Filed December 28, 1955.

Attorney(s) appearing for the Case

Joseph Leo McGroary, Esq., for the petitioners. William Schwerdtfeger, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The Commissioner has determined a deficiency in the income tax of petitioners for the calendar year 1951 in the amount of $2,147.50 and additions to tax under section 294(d)(1)(A) and (d)(2) of the Internal Revenue Code of 1939 in the amount of $3,097.50. Petitioners claim an overpayment in tax. The sole issue for our decision due to petitioners' abandonment of other issues raised in the pleadings is...

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