SAMMONS v. COMMISSIONER

Docket No. 21133-82.

51 T.C.M. 1568 (1986)

T.C. Memo. 1986-318

Myron G. Sammons and Dorothy Sammons v. Commissioner.

United States Tax Court.

Filed July 28, 1986.


Attorney(s) appearing for the Case

James Powers and Marc L. Spitzer, for the petitioners. David W. Otto, for the respondent.


Memorandum Findings of Facts and Opinion

SHIELDS, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                                   Additions to Tax
      Year          Deficiency     Section 6653(a)1

      1977 ........ $140,659.72       $7,032.98
      1978 ........   95,853.94        4,792.69
      1979 ........  165,546...

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