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EPSTEIN v. COMMISSIONER

Docket No. 60243.

18 T.C.M. 455 (1959)

T.C. Memo. 1959-103

Herman Epstein and Martha Epstein v. Commissioner.

United States Tax Court.

Filed May 20, 1959.

Attorney(s) appearing for the Case

Martin S. Eisenberg, Esq., for the petitioners. Norman L. Rapkin, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent has determined a deficiency in the Federal income tax of petitioners for the year 1946 in the amount of $16,783.25, an addition to tax under section 293(b) of the Internal Revenue Code of 1939 in the amount of $8,391.63, and an addition to tax under section 294(d)(2) in the amount of $1,571.47. Respondent's "EXPLANATION OF ADJUSTMENTS" in the statement attached to the notice of deficiency was as follows:

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