CONTI v. COMMISSIONER

Docket No. 15131-90.

64 T.C.M. 1093 (1992)

T.C. Memo. 1992-616.

Guilio J. and Edith Conti v. Commissioner.

United States Tax Court.

Filed October 19, 1992.


Attorney(s) appearing for the Case

Mark C. Pierce, Robert B. Pierce, and Paul T. Mengel, 220 Park St., Birmingham, Mich., for the petitioners. Dennis C. Driscoll, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined deficiencies in income tax of $116,410.57 for 1986 and $390,227.28 for 1987, and additions to tax for fraud under section 6653(b) and substantial understatement of income tax under section 6661.

In the answer respondent alternatively asserted the addition to tax for negligence under section 6653(a). By amended answer, respondent...

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