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BARBER v. COMMISSIONER

Docket No. 5823-76.

39 T.C.M. 1026 (1980)

T.C. Memo. 1980-39

Ronald L. Barber v. Commissioner.

United States Tax Court.

Filed February 12, 1980.

Attorney(s) appearing for the Case

John J. Hentrich, for petitioner. David P. Fuller, for respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in income tax due from the petitioner for the taxable year 1972 in the amount of $147,682 together with the addition to the tax under section 6653(b)1 in the amount of $73,841. At the trial, respondent conceded that the determination should be reduced on account of respondent's overstatement of unreported income attributable to the petitioner...

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