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ESTATE OF EDWARDS v. COMMISSIONER

Docket No. 6619-76.

37 T.C.M. 1345 (1978)

T.C. Memo. 1978-325

Estate of Samuel Edwards, Deceased, Max Sherman, Executor v. Commissioner.

United States Tax Court.

Filed August 17, 1978.

Attorney(s) appearing for the Case

William L. Ringuette and Christopher J. Ray, for the respondent.

Memorandum Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioner's1 Federal income tax for the taxable year 1969 in the amount of $28,359.83 and an addition to tax under section 6653(b)2 in the amount of $14,179.91.

In the absence of adequate books and records, respondent reconstructed petitioner's income using the net worth and expenditures method, and the deficiency notice...

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