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VUITCH v. COMMISSIONER

Docket No. 28479-81.

49 T.C.M. 860 (1985)

T.C. Memo. 1985-95

Milan M. Vuitch and Florence R. Vuitch v. Commissioner.

United States Tax Court.

Filed March 4, 1985.

Attorney(s) appearing for the Case

Robert D. Grossman, Jr. and Paul S. Schleifman, for the petitioners. Ruud L. DuVall, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated August 26, 1981, respondent determined a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1975 in the amount of $129,430. Pursuant to section 6653(a),1 respondent also sought an addition to tax of $6,472. The issues before us are: (1) whether bank deposits totaling $190,750 constitute income to petitioners...

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