DOYLE v. COMMISSIONER

Docket No. 16340-87.

57 T.C.M. 1436 (1989)

T.C. Memo. 1989-463

James S. Doyle v. Commissioner.

United States Tax Court.

Filed August 29, 1989.


Attorney(s) appearing for the Case

Bruce A. Hochstetler, 154 S. Halifax Ave., Daytona Beach, Fla., for the petitioner. Steve R. Johnson, for the respondent.


Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $4,352 in petitioner's income tax for 1983, an addition to tax of $218 under section 6653(a)(1), and a further addition under section 6653(a)(2) equal to 50 percent of the interest due on the deficiency of $4,352.1

The issues for decision are: (1) Whether petitioner's tax home was in Angola for purposes of the section 911 foreign...

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