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SHELDON v. COMMISSIONER

Docket No. 18208-85.

94 T.C. 738 (1990)

STEVEN R. SHELDON AND ELLEN G. SHELDON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 29, 1990.

Attorney(s) appearing for the Case

Vincent R. Barrella, Morton A. Smith, Alice Yaker, and Steven D. Goldberg, for the petitioners.

Edward J. Roepsch and James Hardaker, for the respondent.

GERBER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $56,133 and liability for the increased rate of interest under section 6621(c)1 for taxable year 1981. In an amended answer, respondent also asserted that petitioners are liable for the section 6653(a)(1) and (2) additions to tax for negligence or intentional disregard of rules and regulations. The issues for our consideration are...

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