KELLY v. COMMISSIONER

Docket No. 31271-84.

53 T.C.M. 133 (1987)

T.C. Memo. 1987-89

Charles Kevin Kelly v. Commissioner.

United States Tax Court.

Filed February 12, 1987.


Attorney(s) appearing for the Case

Lawrence J. Hracho and J. Peter Landis, for the petitioner. Thomas E. Crowe, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined a deficiency in petitioner's 1983 Federal income tax in the amount of $20,321 plus additions to tax in the amount of $1,016 and 50 percent of the interest due on $20,321, pursuant to sections 6653(a)(1) and (2),1 respectively. The issues for consideration are:

(1) Whether respondent correctly reconstructed petitioner's taxable income for 1983...

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