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COLEMAN v. COMMISSIONER

Docket No. 48659-86.

60 T.C.M. 874 (1990)

T.C. Memo. 1990-509

Delbert W. Coleman and Karen A. Graham v. Commissioner.

United States Tax Court.

Filed September 25, 1990.

Attorney(s) appearing for the Case

Henry G. Zapruder, David J. Fischer, and Roger A. Pies, 1001 Twenty-Second St., N.W., Washington, D.C., for the petitioners. Michael D. Wilder, for the respondent.

Supplemental Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By timely statutory notice respondent determined a deficiency in petitioners' 1975 Federal income tax of $184,226 and the increased rate of interest on a substantial underpayment attributable to a tax-motivated transaction under section 6621(c)(1).1 This case is presently before us on petitioners' Motion for Reconsideration of our opinion in Coleman v. Commissioner...

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