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COHEN v. COMMISSIONER

Docket No. 13508-85.

56 T.C.M. 629 (1988)

T.C. Memo. 1988-525

Alan J. Cohen and Dorothy E. Cohen v. Commissioner.

United States Tax Court.

Filed November 10, 1988.

Attorney(s) appearing for the Case

Steven S. Brown, Harvey M. Silets, Royal B. Martin, Jr. and Leigh D. Roadman, 140 S. Dearborn St., Chicago, Ill., for the petitioners. Gary Walker and Kirk Chaberski, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1981 and 1982 in the amounts of $260,978.34 and $161,475.50, respectively, and further determined that petitioners were liable for the increased interest rate provided for under I.R.C. sec. 6621(c).1

Some of the issues raised by the pleadings...

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