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ROGERS v. COMMISSIONER

Docket No. 16645-85.

52 T.C.M. 950 (1986)

T.C. Memo. 1986-529

Kenneth A. Rogers and Audrey J. Rogers v. Commissioner.

United States Tax Court.

Filed October 27, 1986.

Attorney(s) appearing for the Case

Steven M. Chamberlain and William E. Whitley, for the petitioners. Willie Fortenberry, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $24,772 in petitioners' Federal income tax for 1981. Also at issue are additions to tax in the amount of $1,239 under section 6653(a)(1)1 and for 50 percent of the interest due on an underpayment of $24,772 under section 6653(a)(2). The only substantive issue for determination is whether a $50,000 wire transfer to petitioners...

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