United States Tax Court October 6, 1969, Docket No. 4470-68 (Reily v. Commissioner)

lead-opinion

Mulroney, Judge:

Respondent determined deficiencies in petitioners’ income tax as follows:

Addition to tax, sec. 6658(a), Year Deficiency I.R.C.1954[1]

1962_____ $1, 354. 52 $67. 73

1963_967.57 48. 38

1964_____ 463. 07 23. 15

Tbe issues are (1) wbetber an “Option to Lease” sold on February 23, 1962, bad been beld by petitioner James S.