CLEVENGER v. COMMISSIONER

Docket Nos. 5586-80, 10545-80, 23106-80, 3753-81.

51 T.C.M. 835 (1986)

T.C. Memo. 1986-149

Clifton Clevenger v. Commissioner. Catherine Clevenger v. Commissioner.

United States Tax Court.

Filed April 15, 1986.


Attorney(s) appearing for the Case

Harrison M. Robertson, for the petitioner in Docket Nos. 5586-80, 23106-80, and 3753-81. Alan M. Schwartz, for the petitioner in docket No. 10545-80. Lawrence D. Garr, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in petitioners' joint Federal income tax and determined additions to tax due to fraud under section 6653(b)2 as follows:

Clifton Clevenger ("Clifton")3

                       Deficiency    Addition

     1973 .........  $ 50,087.85   $25,043.92
     1974 ...........  92,958.20...

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