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HARVEY v. COMMISSIONER

Docket No. 5425-82.

46 T.C.M. 1532 (1983)

T.C. Memo. 1983-599

James F. Harvey v. Commissioner.

United States Tax Court.

Filed September 26, 1983.

Attorney(s) appearing for the Case

Laurence J. Pino, for the petitioner. John F. Driscoll and Willie Fortenberry, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined that petitioner James F. Harvey was liable for a deficiency of $8,283.95 and for additions to tax under section 6653(a)1 ($414.19) and section 6651(a)(1) ($202.65), in his 1980 Federal income tax. By amended answer respondent asserted that petitioner was liable for the addition to tax for fraud under section 6653(b), rather than for negligence as he...

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