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CRAPITTO v. COMMISSIONER

Docket No. 39502.

14 T.C.M. 252 (1955)

T.C. Memo. 1955-77

Anthony F. Crapitto and Lena Crapitto v. Commissioner.

United States Tax Court.

Filed March 31, 1955.

Attorney(s) appearing for the Case

Ben F. Foster, Esq., John E. Pledger, Sr., Esq., and John E. Pledger, Jr., Esq., for the petitioners. Edward L. Compton, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a $20,065.68 deficiency in petitioners' income tax for 1946 and a $10,032.84 addition to tax for fraud. The deficiency was based on the addition to the $2,442.58 net income reported on petitioners' joint return of "Unreported income $40,978.12." The Commissioner explained this addition to petitioners' net income in the following manner:

  Increase in net worth during 1946 .....    $36...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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