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MOWEN v. MOWEN

Docket No. 18501-84.

51 T.C.M. 314 (1986)

T.C. Memo. 1986-25

James E. Mowen and Diane M. Mowen.

United States Tax Court.

Filed January 22, 1986.

Attorney(s) appearing for the Case

James E. Mowen, Hagerstown, Md., for the petitioners. Robert Miller, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency for the calendar year 1980 against petitioners for income tax and self-employment tax in the amount of $58,392, plus additions to tax under section 6653(b)1 in the amount of $29,196. We are called upon to determine whether petitioners understated their taxable income in the year 1980, resulting from their dealings in precious metals...

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