COIT v. COMMISSIONER

Docket No. 5752-78.

54 T.C.M. 816 (1987)

T.C. Memo. 1987-509

Robert S. Coit v. Commissioner.

United States Tax Court.

Filed September 29, 1987.


Attorney(s) appearing for the Case

Christopher M. Weil and Anthony Petrocchi, 1900 North Tower, Dallas, Tex., for the petitioner. Jayne M. Wessels and A. Shawn Noonan, for the respondent.


Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice of deficiency dated March 8, 1978, respondent determined deficiencies in petitioner's and his wife's joint Federal income tax liabilities for 1971, 1972, and 1973, as follows:

                      Addition to Tax
Year   Deficiency   Sec. 6653(a) I.R.C.1

1971   $668,514             -0-
1972    170,680     ...

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