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DOBBS v. COMMISSIONER

Docket No. 32593-84.

53 T.C.M. 1416 (1987)

T.C. Memo. 1987-361

Frederick H. Dobbs and Sherrill R. Dobbs v. Commissioner.

United States Tax Court.

Filed July 23, 1987.

Attorney(s) appearing for the Case

Stephen G. Salley and Allison E. Sundberg, for the petitioners. Gary F. Walker, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the years 1980 and 1981 in the amounts of $20,700 and $24,047, respectively.

By first amendment to answer respondent claimed for each of the years 1980 and 1981 the increased interest rate on deficiencies with respect to substantial underpayments attributable to tax motivated transactions, pursuant to

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