ADKINS v. COMMISSIONER

Docket No. 24124-81.

46 T.C.M. 1166 (1983)

T.C. Memo. 1983-506

James O. Adkins and Joyce R. Adkins v. Commissioner.

United States Tax Court.

Filed August 22, 1983.


Attorney(s) appearing for the Case

James O. Adkins and Joyce R. Adkins, pro se, Germanton, N.C. James E. Grey, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1978 of $5,687 and imposed additions to tax in the amount of $2,843.50 under section 6653(b).1 In his answer, respondent asserted that in the event petitioners are not liable for additions to tax under section 6653(b), then additions to tax should be imposed under section 6653(a) in the amount...

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