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PRATHER v. COMMISSIONER

Docket No. 2340-67.

50 T.C. 445 (1968)

JOHN V. PRATHER AND HELEN PRATHER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 10, 1968.

Attorney(s) appearing for the Case

Arthur J. Whalen, Jr., for the petitioner.

Andrew S. Coxe and Hugh C. McMahon, for the respondent.

OPINION

WITHEY, Judge:

The Commissioner, on June 16, 1967, filed a motion to dismiss this proceeding for lack of jurisdiction. The question presented for decision is whether section 6871 of the Internal Revenue Code1 denies the Court jurisdiction to redetermine deficiencies and additions to tax on the facts as set out below.

John V. Prather, hereinafter referred to as the petitioner, and Helen Prather, were husband...

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