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STERN v. COMMISSIONER

Docket No. 7560-78.

48 T.C.M. 605 (1984)

T.C. Memo. 1984-383

Martin Stern v. Commissioner.

United States Tax Court.

Filed July 25, 1984.

Attorney(s) appearing for the Case

J. Fleet Cowden, for the petitioner. Michael R. Morris, and Christine B. Barish, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioner's Federal income tax and additions to tax for 1970 and 1971 as follows:

                            Additions to Tax
                             Under Sections
  Year      Deficiency        6653(b)1 6654

  1970 ... $391,574.64    $199,287.32   $12,649.39
  1971 ...  415,921.37     207,960.69    13,309.48...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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