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SWICEGOOD v. COMMISSIONER

Docket No. 15953-87.

57 T.C.M. 1456 (1989)

T.C. Memo. 1989-467

Billy Lee Swicegood and Carolyn Lowder Swicegood v. Commissioner.

United States Tax Court.

Filed August 29, 1989.

Attorney(s) appearing for the Case

William E. West, Jr., for the petitioners. Frank D. Armstrong, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $16,914 and additions to tax for 1983 in the amounts of $4,228.50 under section 6661,1 $845.70 under section 6653(a)(1), and 50 percent of the interest due on $16,914 under section 6653(a)(2). The issues for decision are (1) whether petitioners are entitled to the foreign earned income...

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