HANANEL v. COMMISSIONER

Docket No. 16969-89.

62 T.C.M. 439 (1991)

T.C. Memo. 1991-386

Abraham S. and Ruth Hananel v. Commissioner.

United States Tax Court.

Filed August 12, 1991.


Attorney(s) appearing for the Case

Sharon Cormack Mize and Max Nathan, Jr., 201 St. Charles Ave., New Orleans, La., for the petitioner. Emile L. Hebert, III and Linda J. Bourquin, for the respondent.


Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In a deficiency notice dated April 14, 1989, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:

                           Additions to tax under sections
  Year     Deficiency   6653(a)(1)1     6653(a)(2)        6661

12/31/82   $15,967.25     $966.31     50% of the...

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