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BYRNE v. COMMISSIONER

Docket Nos. 9464-79, 14086-79, 14087-79.

44 T.C.M. 338 (1982)

T.C. Memo. 1982-373

Joseph P. Byrne et al. v. Commissioner.

United States Tax Court.

Filed June 30, 1982.

Attorney(s) appearing for the Case

Luther J. Avery, 601 Montgomery St., San Francisco, Calif., Jeffrey S. Ross, 407 Sansome St., San Francisco, Calif., and Michele D. Robertson, 601 Montgomery St., San Francisco, Calif., for the petitioner in Docket No. 6464-79. Herman C. Meyer,1a for the petitioners in Docket Nos. 14086-79 and 14087-79. George L. Bevan, Jr., and David L. Denier, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in the Federal income tax of Joseph P. Byrne and Theresa A. Byrne for the calendar years 1972 and 1973 in the amounts of $173,944 and $40,939, respectively, and additions to tax under section 6653(b)2 in the amounts of $86,972 and $20,469.50, respectively.3 Respondent determined deficiencies in the Federal income...

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