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REED v. COMMISSIONER

Docket No. 777-62.

22 T.C.M. 819 (1963)

T.C. Memo. 1963-173

George W. Reed and Ruth M. Reed v. Commissioner.

United States Tax Court.

Filed June 24, 1963.

Attorney(s) appearing for the Case

Alfred E. Holland, "J" St. Bldg., Sacramento, Calif., for the petitioners. John Hargrove, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners income tax for the taxable years 1951 and 1952 in the amounts of $104,646.75 and $14,409.76, respectively, and an addition to tax under section 294 (d)(2) of the Internal Revenue Code of 1939 in the amount of $7,848.40 for the year 1951.

A number of the issues raised by the pleadings have been disposed...

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