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SMITH v. COMMISSIONER

Docket No. 2879-66.

26 T.C.M. 1017 (1967)

T.C. Memo. 1967-206

T. Michael Smith v. Commissioner.

United States Tax Court.

Filed October 20, 1967.

Attorney(s) appearing for the Case

John A. Overholt, for the petitioner. Harvey I. Lapin, for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in petitioner's income tax liability for the years 1960 and 1961 in the respective amounts of $15.50 and $10,835.69. Respondent's adjustments to petitioner's gross income for 1960 resulting in the deficiency of $15.50 for that year and the explanations thereof are set out in the statement attached to the notice of deficiency as follows:

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