SMOOT v. COMMISSIONER

Docket No. 33352-87.

61 T.C.M. 2897 (1991)

T.C. Memo. 1991-268

Norman E. Smoot and Tommi L. Smoot v. Commissioner.

United States Tax Court.

Filed June 11, 1991.


Attorney(s) appearing for the Case

Donald W. Muir, Jr., and Irwin D. Zucker, 8000 IH 10 West, San Antonio, Tex., for the petitioners. Bruce W. Kent, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                                      Additions to Tax and Increased Interest
Year                Deficiency   Sec. 6653(a)(1)1   Sec. 6653(a)(2)    Sec. 6661   Sec. 6621(c)

1983 ............   $57,508.00     ...

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