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BEATON v. COMMISSIONER

Docket No. 1884-77.

40 T.C.M. 1324 (1980)

T.C. Memo. 1980-413

Colin F. and Eleanor M. Beaton v. Commissioner.

United States Tax Court.

Filed September 22, 1980.

Attorney(s) appearing for the Case

Kenneth F. Kane, for the petitioners. Thomas P. Dougherty, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $50,821.03 in the petitioners' Federal income tax for 1973 and additions to tax for such year of $12,705.26 under section 6651(a) of the Internal Revenue Code of 19541 and $2,541.05 under section 6653(a). After concessions by the petitioners, the issues to be decided are: (1) Whether Mr. Beaton is taxable in 1973 on certain funds...

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