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HIGH v. COMMISSIONER

Docket Nos. 42910, 42911.

15 T.C.M. 91 (1956)

T.C. Memo. 1956-18

Paul J. High and Fay High v. Commissioner. Paul J. High v. Commissioner.

United States Tax Court.

Filed January 23, 1956.

Attorney(s) appearing for the Case

Lawrence G. Ropes, Jr., Esq., and H. P. Forrest, Esq., 228 North East Second Street, Miami, Fla., for the petitioners. Hugh F. Culverhouse, Esq., and Hugh G. Isley, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined deficiencies in income tax of petitioner in Docket No. 42911, and additions thereto for fraud, for years and in amounts as follows:

                                  50 Percent
                                 Addition for
  Year              Deficiency      Fraud

  1945...........    $ 597.40      $ 298.70
  1946...........    7,824.94      3,912.47

The respondent also...

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