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COHEN v. COMMISSIONER

Docket Nos. 4290-69, 3614-70, 3927-71, 6145-72, 7823-74, 6244-75.

42 T.C.M. 312 (1981)

Sam Cohen and Ethel Cohen. Samuel (a/k/a Sam) Cohen and Ethel Cohen v. Commissioner.

United States Tax Court.

July 2, 1981.

Memorandum Sur Order

WILBUR, Judge:

By separate notices of deficiency, respondent determined the following amounts due from petitioners for Federal income taxes and imposed the following penalties:

  Taxable                            Sec. 6653(b)1
   Year                 Deficiency      Penalty

  1963 ..............  $   647,772.94  $  323,886.47
  1964 ..............      822,325.41     411,162.71
  1965 ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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