Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1961 of $13,678.14, and additions to tax for fraud under section 6653(b), I. R. C. 1954 of $6,839.07, and for underpayment of estimated tax under section 6654(a), I. R. C. 1954, of $108.89. At issue is whether petitioner Paul A. Gorin, a lawyer, received a cash payment in 1961 of $28,500 as part of his fee for handling a tax fraud case...
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