EMERSHAW v. COMMISSIONER

Docket No. 23223-87.

59 T.C.M. 621 (1990)

T.C. Memo. 1990-246

George J. and Virginia D. Emershaw v. Commissioner.

United States Tax Court.

Filed May 21, 1990.


Attorney(s) appearing for the Case

Richard P. Swanson and Jennifer B. Ungar, 520 Madison Ave., New York, N.Y., for the petitioners. Elizabeth P. Flores and Martin L. Shindler, for the respondent.


Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined the following deficiencies in and additions to petitioners' Federal income tax:

                                                 Additions to Tax
                                                  Under Sections1
Year                    Deficiency    6653(a)(1)    6653(a)(2)        6661
1983...

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