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PAOLI v. COMMISSIONER

Docket No. 42511-85.

54 T.C.M. 1574 (1988)

T. C. Memo. 1988-23

Stephen A. Paoli and Betty Mae Paoli v. Commissioner.

United States Tax Court.

Filed January 21, 1988.

Attorney(s) appearing for the Case

William J. Gerard, Three 1st. Natl. Plaza, Chicago, Ill., for the petitioners. Teri A. Frank, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $30,297 in petitioners' Federal income taxes for 1981 and additions to tax of $1,515 under section 6653(a)(1)1 and 50 percent of the interest due on $30,297 under section 6653(a)(2). The deficiency resulted from respondent's determination that interest on petitioners' margin accounts at various brokerage firms was subject to section 163...

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