O'Brien v. Comm'r

James F. X. O'Brien v. Commissioner.

O'Brien v. Comm'r

Docket No. 3762.

United States Tax Court

1945 Tax Ct. Memo LEXIS 293; 4 T.C.M. (CCH) 221; T.C.M. (RIA) 45069;

February 15, 1945

James F. X. O'Brien, pro se, and David Zuckerman, C.P.A., for the petitioner. Jonas M. Smith, Esq., for the respondent.

ARUNDELL

Memorandum Findings of Fact and Opinion

This proceeding involves a deficiency in income tax of $22,971.78 and the imposition of a five per cent ad valorm penalty amounting to $1,148.59 for the taxable year 1939. Several questions have been raised by the parties. They are: (1) Whether the income…