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WALKER v. COMMISSIONER

Docket No. 44463-85.

60 T.C.M. 1340 (1990)

T.C. Memo. 1990-609

L.A. Walker III and Linda J. Walker v. Commissioner.

United States Tax Court.

Filed December 4, 1990.

Attorney(s) appearing for the Case

Kenton E. McDonald, 1800 First City, Corpus Christi, Tex., Farley Katz, and C.J. Muller, for the petitioners. C. Joseph Craven, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1979 of $226,943.74, and an addition to tax under section 6653(a)1 for taxable year 1979 of $11,347.19. Respondent also determined that petitioners are liable for an increased rate of interest pursuant to section 6621(c) due to a substantial underpayment attributable to a tax motivated...

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