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McALPINE v. COMMISSIONER

Docket No. 15347-80.

47 T.C.M. 1403 (1984)

T.C. Memo. 1984-162

Lawrence L. McAlpine and Celeste W. McAlpine v. Commissioner.

United States Tax Court.

Filed April 2, 1984.

Attorney(s) appearing for the Case

R.D. Worsley and John W. Ambrecht, 205 East Figueroa St., Santa Barbara, Calif. 93101, for the petitioners. Marc J. Winter, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined that for the year 1976 there was due from the petitioners a deficiency in income tax in the amount of $33,621, excise tax in the amount of $90 under section 4973,1 and an addition to tax under section 6653(b) of $16,811. Prior to trial, several issues were conceded by the parties including a concession by the petitioners that the statutory notice was...

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