SCHAD v. COMMISSIONER

Docket Nos. 26148-84, 28216-84.

87 T.C. 609 (1986)

MARK G. SCHAD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 17, 1986.


Attorney(s) appearing for the Case

Thomas G. Christmann and Walter M. Tovkach, for the petitioner.

Francis C. Mucciolo, for the respondent.


FEATHERSTON, Judge:

Respondent determined in docket No. 28216-84 that petitioner is liable to the extent of $300,000 as transferee of Joseph F. Collins, deceased. Respondent also determined in docket No. 26148-84 a deficiency in the amount of $93,779 in petitioner's 1983 income tax together with additions to tax in the amount of $9,193 under section 6651(a)(1),1 $4,689 under section 6653(a)(1), $5,521 under section 6654, and 50...

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