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AULD v. COMMISSIONER

Docket No. 9509-76.

37 T.C.M. 1851 (1978)

T.C. Memo. 1978-508

Finley G. Auld and Virginia Auld v. Commissioner.

United States Tax Court.

Filed December 26, 1978.

Attorney(s) appearing for the Case

Edwin Fradkin, Harvey R. Zeller, John J. O'Toole, and Edwin N. Gross, 744 Broad St., Newark, N.J., for the petitioners. Steven I. Klein, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency and an addition to tax under section 6653(a), Internal Revenue Code of 1954,1 for the taxable year 1973 in the respective amounts of $45,428.30 and $2,334.74. The issues for our decision are:

(1) Whether petitioners have the burden of proof with respect to the question of whether petitioner's son, Gregory T. Auld, became a shareholder...

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