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KINGSLEY v. COMMISSIONER

Docket No. 11439-87.

58 T.C.M. 1428 (1990)

T.C. Memo. 1990-79

Michael J. Kingsley v. Commissioner.

United States Tax Court.

Filed February 20, 1990.

Attorney(s) appearing for the Case

Elliot D. Lobel, 222 Lewis Wharf, Boston, Mass., for the petitioner. Charles Maurer, for the respondent.

Memorandum Findings of Fact and Opinion

Ruwe, Judge:

On December 12, 1986, a jeopardy assessment was made against petitioner for taxable years 1980, 1981, 1982, 1983, and 1984 pursuant to section 6861(a).1 In a notice of deficiency dated February 3, 1987, respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

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