Memorandum Opinion
RAUM, Judge:
In a notice of deficiency dated April 8, 1963, and addressed to petitioner Charles G. Griebel, II, individually, the Commissioner determined a deficiency in income tax for 1958 in the amount of $64,931.90 plus a so-called five percent penalty in the amount of $3,242.
The deficiency was based upon an adjustment that charged petitioner with having received a $115,459.38 dividend from Griebel Realty, Inc. That corporation...
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