Haldane M. Plunkett v. Commissioner of Internal Revenue

PELL, Circuit Judge.

In 1968, taxpayer Haldane M. Plunkett filed two petitions in the Tax Court challenging the Commissioner’s determinations regarding deficiencies in income tax, additions to tax, and alleged over-payments. The two petitions, one involving the years 1957 through 1959 and the other 1960 through 1963, were consolidated for trial and decision. 1 On Oc tober 2, 1970, the Tax Court entered its decisions sustaining a deficiency of $9,-504.96 for the taxable year 1957 and additions to tax under 26 U.S.C. § 6653(b) 2 of $35,141.10 for the years 1957 through 1963. 3 After the Tax…