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AVERY v. COMMISSIONER

Docket No. 796-74.

35 T.C.M. 577 (1976)

T.C. Memo. 1976-129

Alice R. Avery v. Commissioner.

United States Tax Court.

Filed April 22, 1976.

Attorney(s) appearing for the Case

Robert E. Kovacevich, for the petitioner. Thomas N. Tomashek, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a deficiency in petitioner's 1972 Federal income tax of $11,845.97. Respondent also asserted a penalty of $1,128.36 under section 6651(a)1 for late filing of a return, and a penalty of $592.30 under section 6653(a) for negligent underpayment of tax.

The following issues are presented for decision:

(1) Whether petitioner had unreported income...

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