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MOORE v. COMMISSIONER

Docket No. 18241-80.

47 T.C.M. 256 (1983)

T.C. Memo. 1983-671

Sam E. Moore and Diane R. Lowry, formerly Diane R. Moore v. Commissioner.

United States Tax Court.

Filed November 8, 1983.

Attorney(s) appearing for the Case

William R. Baldwin, III, 629 East Main St., Richmond, Virginia, William J. Irvin and Mahlon G. Funk, Jr., for the petitioners. Scott D. Anderson, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined deficiencies and additions to tax for the years 1975 and 1976 as follows:

                              Addition to Tax
  Year            Deficiency   Sec. 6653(a)1
__________________________________________________
  1975 .......... $28,725.72    $1,436.29
  1976 ..........  15,882.11       794.11

The sole issue is whether...

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