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PATEL v. COMMISSIONER

Docket No. 4542-85.

55 T.C.M. 2 (1988)

T.C. Memo. 1988-33

Chandrakant B. Patel and S.C. Patel v. Commissioner.

United States Tax Court.

Filed February 1, 1988.

Attorney(s) appearing for the Case

Steven R. Wolfson, 4144 N. Central Expwy., Dallas, Tex., and Joy C. Al-Sofi, for the petitioners. Donna K. Robason, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $162,175.41 for 1979 and $152,547.25 for 1980. In addition, he determined that the petitioners were liable for the addition to tax under section 6653(a), Internal Revenue Code of 1954,1 of $8,108.77 for 1979 and $7,627.36 for 1980. After concessions by both parties, the issues for our decision...

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