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RESSER v. COMMISSIONER

Docket No. 18606-88.

62 T.C.M. 617 (1991)

T.C. Memo. 1991-423

Alan M. Resser and Melinda B. Resser v. Commissioner.

United States Tax Court.

Filed August 27, 1991.

Attorney(s) appearing for the Case

Charles R. Levun and John V. Ryan III, for the petitioners.

Joseph T. Ferrick and James C. Lanning, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1982 in the amount of $391,113.00, and an addition to tax under section 66611 for taxable year 1982 in the amount of $97,778.50. Respondent also determined that petitioners are liable for an increased rate of interest pursuant to section 6621(c) due to a substantial underpayment attributable...

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