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STEPHENS v. COMMISSIONER

Docket No. 48914.

15 T.C.M. 1471 (1956)

T.C. Memo. 1956-284

O. E. Stephens v. Commissioner.

United States Tax Court.

Filed December 31, 1956.

Attorney(s) appearing for the Case

Marion Hirschburg, Esq., 300½ Main Street, Ames, Ia., Rex B. Gilchrist, Esq., and Don Bowman, Esq., for the petitioner. Marvin E. Hagen, Esq., and Frank C. Conley, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined a deficiency in income tax for the calendar year 1947 in the amount of $4,853.80 and a 50 per cent addition thereto for fraud in the amount of $2,426.90.

The additional income upon which the deficiency is based was determined by the respondent on an increase in the petitioner's net worth plus personal and nondeductible...

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