MALICKI v. COMMISSIONER

Docket Nos. 25157-84, 888-85.

56 T.C.M. 814 (1988)

T.C. Memo. 1988-559

Michael J. Malicki and Kathleen Malicki v. Commissioner. Gold Emporium, Inc. v. Commissioner.

United States Tax Court.

Filed December 8, 1988.


Attorney(s) appearing for the Case

Robert E. Dallman, 111 E. Wisconsin Ave., Milwaukee, Wis., and John A. Sikora, 700 N. Water St., Milwaukee, Wis., for the petitioners. James M. Klein, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies and additions to tax in petitioners' Federal income taxes as follows:

         Michael J. and Kathleen Malicki

                                   Addition to Tax
Year             Deficiency        Section 6653(b)2

1980 ..........  $445,572.82        $222,786.41*

* The addition to...

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