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SOLOW v. COMMISSIONER

Docket No. 75595.

22 T.C.M. 398 (1963)

T.C. Memo. 1963-87

Ralph J. Solow and Celia O. Solow v. Commissioner.

United States Tax Court.

Filed March 27, 1963.

Attorney(s) appearing for the Case

Mason G. Kassel, Esq., and David R. Frazer, Esq., for the petitioners. John J. Hopkins, Esq., and Alvin C. Martin, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency of $711,646.86 in petitioners' income tax for the calendar year 1950 and a deficiency in income tax of $8.94 and additions to tax of $286.09 and $190.74 under sections 294(d)(1)(A) and (d)(2),1 respectively, for the calendar year 1951. Petitioners have conceded the deficiency for 1951. Petitioners have not met their burden of proof...

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