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WHITE v. COMMISSIONER

Docket No. 16976-88.

60 T.C.M. 538 (1990)

T.C. Memo. 1990-439

Robert H. White and Judy K. White v. Commissioner.

United States Tax Court.

Filed August 15, 1990.

Attorney(s) appearing for the Case

John N. Moore, 30040 Aurora Rd., Solon, Ohio, for the petitioners.

Dawn M. Krause, for the respondent.

Memorandum Opinion

PAJAK, Special Trial Judge.

This case was heard pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code for the taxable year in issue. All rule numbers refer to the Tax Court Rules of Practice and Procedure.)

Respondent determined a deficiency in petitioners' 1984 Federal income tax of $1,378.00 and additions to tax under section 6653(a)(1) of

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