United States Tax Court, 1959

Lozoski v. Commissioner

United States Tax Court · Decided November 30, 1959

18 T.C.M. 1062; 1959 Tax Ct. Memo LEXIS 19; 1959 T.C. Memo. 221

Opinion

Vincent F. Lozoski and Mary F. Lozoski v. Commissioner.

Docket No. 65083.

United States Tax Court

T.C. Memo 1959-221; 1959 Tax Ct. Memo LEXIS 19; 18 T.C.M. (CCH) 1062; T.C.M. (RIA) 59221;

November 30, 1959

*19 Paul A. Gorin, Esq., for the petitioners. Manning K. Leiter, Esq., for the respondent.

OPPER

Memorandum Opinion

OPPER, Judge: Respondent determined deficiencies in additions to tax as follows:

	Additions to tax - I.R.C. 1939
Year	Sec. 294(d)(1)(A)	Sec. 294(d)(2)
1953	$362.44	$255.84
1954	108.19	76.37

The sole issue is whether the additions to tax provided by section 294(d)(1)(A) and section 294(d)(2), I.R.C. 1939, may be concurrently imposed, in the absence of any declaration.

All of the facts are stipulated and are hereby found.

This case is concededly indistinguishable from Commissioner v. Acker, - U.S. - (decided Nov. 16, 1959). On the authority thereof the issue must be decided in petitioners' favor.

Decision will be entered under Rule 50.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.