Overman v. Commissioner

J. A. Overman v. Commissioner.

Overman v. Commissioner

Docket No. 45318.

United States Tax Court

1953 Tax Ct. Memo LEXIS 1; 12 T.C.M. (CCH) 1453; T.C.M. (RIA) 54009;

December 31, 1953

John O. Durkan, Esq., for the respondent.

OPPER

Memorandum Findings of Fact and Opinion

OPPER, Judge: Respondent determined deficiencies against petitioner as follows:

"6% Penalty for

"5%

Substantial

Delinquency

"50% Civil

Underestimation

Income

Penalty

Fraud Penalty

of Estimated Tax

Tax

Sec. 291(a)"

Sec. 293(b)"

Sec. 294(d)(2)"

1946

$ 3,951.19

$ 197.56

$ 1,975.60

$ 220.01

1947

37,803.18

18,901.59

2,271.79

At the hearing petitioner failed to…