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SAFFAN v. COMMISSIONER

Docket No. 56629.

16 T.C.M. 822 (1957)

T.C. Memo. 1957-184

Samuel Saffan v. Commissioner.

United States Tax Court.

Filed September 30, 1957.

Attorney(s) appearing for the Case

John F. Dailey, Jr., Esq., and Samuel Goldwasser, Esq., for the petitioner. A. Jesse Duke, Jr., Esq., and John A. Dunkel, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined the following deficiencies and additions in regard to petitioner's income tax:

                               Addition to Tax
  Year             Deficiency   Sec. 293(a)

  1945 .........  $35,283.81    $1,764.19
  1946 .........    1,197.59        59.88
  1947 .........      790.05        39.50

The main issue to be decided is whether respondent was correct...

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