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KARPA v. COMMISSIONER

Docket No. 10361-88.

58 T.C.M. 278 (1989)

T.C. Memo. 1989-535

Jay N. Karpa and Elizabeth J. Karpa v. Commissioner.

United States Tax Court.

Filed September 27, 1989.

Attorney(s) appearing for the Case

Jay Fred Cohen, 100 Church Ln., Baltimore, Md., for the petitioners. Clare J. Brooks, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This matter is before the Court on the parties' cross motions for judgment on the pleadings under Rule 120.1 The sole issue to be resolved is whether the retroactive increase in the addition to tax from 10 percent to 25 percent under section 6661 (substantial understatement of liability), enacted in 1986 is prohibited by the Constitution of the United...

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