United States Tax Court August 31, 1964, Docket No. 3157-62 (Klein v. Commissioner)

lead-opinion

OPINION

Black, Judge:

The Commissioner has determined deficiencies in petitioners’ income tax and additions to tax under sections 6653(a) and 6651(a), I.R.C. 1954, for the years 1957, 1958, 1959, and 1960.

The adjustments to taxable income for 1957 included: “(a) Income from sale of partnership assets and interest $33,169.38.