Leroy Jewelry Co. v. Commissioner

Drennen, Judge:

Respondent determined deficiencies in petitioner’s income tax for its fiscal years ending June 30,1956 and 1957, in the amounts of $2,145.36 and $22,437.93, respectively, and an addition to tax for the fiscal year 1957 in the amount of $1,121.90 under the provisions of section 6653(a) of the Internal Revenue Code of 1954. The parties have stipulated the amount of the deficiency for each year and the amount of the addition to tax for the fiscal year 1957 in the event the Court finds the addition to tax applicable. Thus, the only issue for decision is whether the addition to tax…