LEVY v. COMMISSIONER

Docket No. 18383-86.

54 T.C.M. 1300 (1987)

T.C. Memo. 1987-609

Stanley S. Levy and Martha R. Levy v. Commissioner.

United States Tax Court.

Filed December 14, 1987.


Attorney(s) appearing for the Case

Robert I. White and George W. Connelly, Jr., 1200 Smith St., Houston, Tex., for the petitioners. David W. Johnson, for the respondent.


Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

This case is before us on cross-motions for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1 The Commissioner determined a deficiency in petitioners' Federal income tax for their 1979 taxable year in the amount of $24,701.00 and an addition to tax for fraud pursuant to section 6653(b)2 against petitioner Stanley...

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