Semel v. Commissioner

Nat Tully Semel v. Commissioner.

Semel v. Commissioner

Docket No. 916-62.

United States Tax Court

T.C. Memo 1965-232; 1965 Tax Ct. Memo LEXIS 97; 24 T.C.M. (CCH) 1176; T.C.M. (RIA) 65232;

August 27, 1965

Jules Ritholz, for the petitioner. Alan L. Swartz, for the respondent.

FORRESTER

Memorandum Findings of Fact and Opinion

FORRESTER, Judge: The respondent determined deficiencies in the petitioner's income tax and additions to the tax as follows:

Addition to Tax

Sec. 6653(a),

Year

Deficiency

I.R.C. 1954

1955

$ 8,117.70

$405.89

1956

9,622.20

1957

9,610.04

$27,349.94

$405.89

Several of the issues raised by the…