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ADAMSON v. COMMISSIONER

Docket No. 17447-80.

44 T.C.M. 327 (1982)

T.C. Memo. 1982-371

Kent A. Adamson v. Commissioner.

United States Tax Court.

Filed June 30, 1982.

Attorney(s) appearing for the Case

John W. Flynn, 315 Second Ave., South, Seattle, Wash. for the petitioner. Wayne R. Appleman, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

The Commissioner determined a deficiency in the amount of $237,723 in petitioner's Federal income tax for 1979, together with additions to tax in the amounts of $11,886 under section 6651(a)1 and $11,886 under section 6653(a). A jeopardy assessment of these amounts plus interest in the amount of $703.40 was made on April 24, 1980. The controlling issue in the case is...

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