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HUMAN ENGINEERING INSTITUTE v. COMMISSIONER

Docket Nos. 528-68, 529-68.

61 T.C. 61 (1973)

HUMAN ENGINEERING INSTITUTE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOSEPH S. KOPAS AND MARY E. KOPAS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 18, 1973.

Attorney(s) appearing for the Case

James F. Sexton and Andrew Lelko, for the petitioners.

Buckley D. Sowards, for the respondent.

OPINION

TANNENWALD, Judge:

The problem presented in this proceeding is rooted in jeopardy assessments, for which notice and demand was made on September 7, 1967, against the individual petitioners in the amount of $3,405,909.01 and the corporate petitioner in the amount of $1,271,053.24. In accordance with the provisions of section 6861(b),1 respondent on November 3, 1967, issued notices of deficiency for the taxable years...

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