Fred N. Acker v. Commissioner of Internal Revenue

MATHES, District Judge.

The Tax Court sustained in toto respondent’s determinations of deficiencies in petitioner’s income tax and additions thereto under Int.Rev.Code of 1939 §§ 291(a), 294(d) (1) (A), and 294(d) (2), 26 U.S.C.A. §§ 291(a), 294(d) (1) (A), (2) for the years 1947-1950 inclusive.

Petitioner does not question here the correctness of the additions to tax under § 291(a), but challenges the validity of all the deficiency determinations and additions to tax under §§ 294(d) (1) (A) and 294(d) (2) for each of the years involved.

The facts, as set out in the Tax Court’s Memorandum…