STEWART v. COMMISSIONER

Docket Nos. 16518-83, 26407-84.

55 T.C.M. 1730 (1988)

T.C. Memo. 1988-402

Robert E. Stewart and Gloria H. Stewart v. Commissioner.

United States Tax Court.

Filed August 29, 1988.


Attorney(s) appearing for the Case

John G. Gourlay, Jr., One Jackson Place, Jackson, Miss., for the petitioners. Robert W. West, for the respondent.


Memorandum Opinion

KÖRNER, Judge:

Respondent determined the following deficiencies and additions to petitioners' income taxes:

                         Tax Year                                    Additions to Tax
       Docket No.         Ended          Deficiency     Sec. 6653(a)(1)2       Sec. 6653(a)(2)

       16518-83         12/31/78        $73,279.80...

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