United States Tax Court August 29, 1973, Docket No. 2284-73 (Dixon v. Commissioner)

lead-opinion

OPINION

Dawson, Judge:

On January 10, 1973, respondent sent the petitioner a timely statutory notice of deficiency, after making a jeopardy assessment, which determined Federal income tax deficiencies and additions to tax, as follows:

Aüdttion to tax see. 6658 (6),

Taxable year Deficiency I.R.G. 165h

1970 _$902, 679.29 $451,339. 65

1971_ 550,514.48 275,257.