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ROGGIN v. COMMISSIONER

Docket No. 11205-81.

50 T.C.M. 216 (1985)

T.C. Memo. 1985-307

Gary M. Roggin v. Commissioner.

United States Tax Court.

Filed June 25, 1985.

Attorney(s) appearing for the Case

Gerald H. Lean, 5700 Smith Ave., Baltimore, Md., for the petitioner. Robert A. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

By notice of deficiency dated February 26, 1981, respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended December 31, 1977 in the amount of $8,394. Pursuant to section 6653(a),1 respondent also sought an addition to tax of $419.70. After concessions, the sole issue before us is whether the amount of distributable income generated...

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