CROWLEY v. COMMISSIONER

Docket No. 10427-88.

60 T.C.M. 1447 (1990)

T.C. Memo. 1990-636

Ralph D. Crowley and Frances A. Crowley v. Commissioner.

United States Tax Court.

Filed December 18, 1990.


Attorney(s) appearing for the Case

James C. Donnelly, Jr., 1700 Mechanics Bank Tower, Worcester, Mass., for the petitioners. Christine Colley and Robert M. Finkel, for the respondent.


Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1981 in the amount of $9,944 and for 1982 in the amount of $206,935. He also determined an addition to tax, pursuant to section 6651(a)(1),1 for 1982 in the amount of $48,061. The section 6651(a)(1) addition to tax was determined because petitioners filed their joint income tax return for 1982 on February...

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