CLARK v. COMMISSIONER

Docket No. 31368-83.

90 T.C. 68 (1988)

JAMES R. CLARK AND LILA V. CLARK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1988.


Attorney(s) appearing for the Case

Melvin M. Engel, for the petitioners.

Ana G. Cummings, for the respondent.


OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

                            Additions to tax
                         ---------------------------------
Year    Deficiency     Sec. 6653(a)1      Sec. 6654

1974   $585,488.12      $29,274.40       $18,693.93
1975     86,591.06        4,329.55         3,730.16...

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