HERZOG v. COMMISSIONER

Docket No. 20378-80, 20379-80.

46 T.C.M. 1536 (1983)

T.C. Memo. 1983-601

Charles W. Herzog v. Commissioner.

United States Tax Court.

Filed September 26, 1983.


Attorney(s) appearing for the Case

Robert C. Rogers, Jr. and 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 the following deficiencies in, and additions to, the Federal income tax of petitioner Charles W. Herzog:

                                   Addition to Tax
  Year           Deficiency    under Sec. 6653(b)1

  1977 ........    $1,630           $  815
  1978 ........     4,978            2,4892

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