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GROSSMAN v. COMMISSIONER

Docket No. 22974-82.

52 T.C.M. 484 (1986)

T.C. Memo. 1986-439

Abraham C. Grossman and Chana Grossman v. Commissioner.

United States Tax Court.

Filed September 15, 1986.

Attorney(s) appearing for the Case

Richard L. Goldman, 36 W. 44th St., New York, N.Y. 10036, for the petitioners. Robert Schneps and Laurence Ziegler, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency in petitioners' 1975 Federal income tax in the amount of $117,315.16 and an addition to tax of $17,597.27 under section 6651(a)(1).1 The parties have settled all issues giving rise to the underlying deficiency in tax. The remaining issues for decision are: (1) whether petitioners' failure to timely file their 1975 tax return was due to reasonable...

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