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KATZ v. COMMISSIONER

Docket Nos. 5077-66, 5824-66.

27 T.C.M. 415 (1968)

T.C. Memo. 1968-88

Max Katz v. Commissioner. Valencia Katz v. Commissioner.

United States Tax Court.

Filed May 15, 1968.

Attorney(s) appearing for the Case

Nathan Wald, 500 Fifth Ave., New York, N. Y., for the petitioner in docket No. 5077-66. Thomas J. Todarelli, 233 Broadway, New York, N. Y., for the petitioner in docket No. 5824-66. Jay S. Hamelburg, for the respondent.

Memorandum Opinion

RAUM, Judge:

Max Katz, petitioner in docket No. 5077-66, and Valencia Katz, petitioner in docket No. 5824-66, are husband and wife. They are legally separated, and their positions are antagonistic to one another in this litigation. The facts have been stipulated.

The Commissioner determined deficiencies in income tax against each of them as follows:

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