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FRANKLIN v. COMMISSIONER

Docket No. 14451-82.

48 T.C.M. 158 (1984)

T.C. Memo. 1984-278

Lindsay D. Franklin v. Commissioner.

United States Tax Court.

Filed May 24, 1984.

Attorney(s) appearing for the Case

Mark E. Rizik, for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year 1980 in the amount of $9,051.40 and an addition to tax for that year in the amount of $452.57 under the provisions of section 6653(a).1 The respondent alleged in an amended answer that the petitioner was liable for a 25 percent addition to tax under the provisions of section 6651(a)(1). The issues for decision are...

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