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GOLDEN v. COMMISSIONER

Docket No. 21693-84.

58 T.C.M. 185 (1989)

T.C. Memo. 1989-514

Martin P. Golden and Regina Golden v. Commissioner.

United States Tax Court.

Filed September 25, 1989.

Attorney(s) appearing for the Case

Martin P. Golden, pro se. Sandra M. Gilmore, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1980 in the amount of $7,702.06. By amendment to answer, respondent asserts that petitioners are liable for an increased rate of interest under section 6621(c),1 on account of a substantial underpayment attributable to a tax motivated transaction. By amendment to petition, petitioners...

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