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STEINER v. COMMISSIONER

Docket No. 51187.

25 T.C. 26 (1955)

L. M. STEINER AND HARRIET T. STEINER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 17, 1955.

Attorney(s) appearing for the Case

Robert J. Johnson, Esq., for the petitioners.

Thomas A. Steele, Jr., Esq., for the respondent.

OPINION.

WITHEY, Judge:

Respondent determined a deficiency of $305.78 in the income tax of petitioners for 1950 and an addition to tax of $1,308.36 under section 294 (d) (2) of the Internal Revenue Code of 1939.

The petitioners concede the correctness of the deficiency in tax determined by respondent. They also concede that if they were liable for an addition to tax under section 294 (d) (2) then the amount thereof as determined by respondent...

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