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O'DEA v. COMMISSIONER

Docket No. 3641-68.

30 T.C.M. 593 (1971)

T.C. Memo. 1971-138

John T. O'Dea, Jr., v. Commissioner.

United States Tax Court.

Filed June 15, 1971.

Attorney(s) appearing for the Case

Robert B. Milgroom, 225 Franklin, Boston, Mass., and George A. Stella, for the petitioner. Robert B. Dugan, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The respondent determined deficiencies in the income tax of the petitioner of $19,371.03 for 1964 and $8,462.41 for 1965 and additions to tax for negligence under section 6653(a) of the Internal Revenue Code of 19541 of $968.55 for 1964 and $423.12 for 1965. The issues for decision are (1) whether the respondent's use of the bank deposit method to reconstruct the petitioner...

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