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WALDROP v. COMMISSIONER

Docket No. 30830-84.

54 T.C.M. 1261 (1987)

T.C. Memo. 1987-600

Patrick M. Waldrop v. Commissioner.

United States Tax Court.

Filed December 7, 1987.

Attorney(s) appearing for the Case

Samuel R. McCord, 1608 13th Ave. South, Birmingham, Ala., for the petitioner. Frank Simmons, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By notice of deficiency dated August 8, 1984, respondent determined a deficiency in tax against petitioner for the calendar year 1978 in the amount of $4,440,570 and an addition to tax under section 6653(b)1 in the amount of $2,220,285. Petitioner was convicted after trial in the United States District Court for the Northern District of Florida on April 26, 1982, of various...

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