KUSHNER v. COMMISSIONER

Docket No. 21488-8.

61 T.C.M. 1716 (1991)

T.C. Memo. 1991-26

Jack Kushner and Annetta H. Kushner v. Commissioner.

United States Tax Court.

Filed January 23, 1991.


Attorney(s) appearing for the Case

Anne W. Mitchell, 1100 Financial Center, Birmingham, Ala., for the petitioners. John F. Driscoll, for the respondent.


Memorandum Opinion

NIMS, Chief Judge:

Respondent determined deficiencies in, additions and increased interest to petitioners' Federal income taxes as follows:

Year                           Deficiency   Section 6659   Section 6661   Section 6621(c)

1982 .......................     $8,111        $1,834         $1,956             *
1983 .......................      7,842          --            2,441      ...

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