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PALANO v. COMMISSIONER

Docket No. 33532-85.

53 T.C.M. 676 (1987)

T.C. Memo. 1987-211

Robert Palano v. Commissioner.

United States Tax Court.

Filed April 27, 1987.

Attorney(s) appearing for the Case

William J. Neild, 144 Exchange Blvd., Rochester, N.Y., for the petitioner. Stephen C. Best, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

For the calendar year 1980 respondent determined a deficiency of $48,552.88 in petitioner's income tax including $676.00 in self-employment tax under section 1401(a), an addition to tax of $4,855.29 under section 6651(a)(1)1 and an addition to tax of $2,427.64 under section 6653(a).

After concessions, the issues for decision are (1) whether petitioner had unreported...

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