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PHILLIPS v. COMMISSIONER

Docket No. 60458.

17 T.C.M. 918 (1958)

T.C. Memo. 1958-183

Dwight A. Phillips and Lucile Phillips, Husband and Wife v. Commissioner.

United States Tax Court.

Filed October 15, 1958.

Attorney(s) appearing for the Case

John R. Jones, Esq., for the petitioners. Miller Bowen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in additions to petitioners' tax as follows:

                           Deficiency
                        Addition to tax
  Year                 Sec. 294    Sec. 294
                      (d)(1)(A)     (d)(2)
  1951 .............   $842.49     $265.50
  1952 .............    571.56      231.04

Petitioners concede that respondent's additions...

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