SCHAEFFER v. COMMISSIONER

Docket No. 9266-76.

41 T.C.M. 752 (1981)

T.C. Memo. 1981-27

Milton T. Schaeffer and Joan H. Schaeffer v. Commissioner.

United States Tax Court.

Filed January 27, 1981.


Attorney(s) appearing for the Case

William H. Lawson, Jr., One Commerce Sq., Memphis, Tenn., for the petitioners. Wesley J. Lynes and Joel Gerber, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' 1973 Federal income tax in the amount of $92,662.95. He further determined an addition to petitioners' tax under section 6651(a)(1), Internal Revenue Code of 1954,1 in the amount of $4,633.15. After concessions (including respondent's concession with regard to the negligence penalty), the sole issue remaining for our...

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