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DANIELS v. COMMISSIONER

Docket No. 3658-90.

64 T.C.M. 1439 (1992)

T.C. Memo. 1992-692

Glenn A. Daniels and Virginia E. Daniels v. Commissioner.

United States Tax Court.

Filed December 7, 1992.

Attorney(s) appearing for the Case

John Andrew Jones, for the petitioners.

Marilyn S. Ames and Richard L. Hunn, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined deficiencies in petitioners' income tax of $32,836.90 for 1980 and $22,611.81 for 1981. Respondent also determined additions to tax for fraud under section 6653(b) for petitioner Glenn A. Daniels of $16,418.45 for 1980 and $11,305.90 for 1981.

Respondent used a net worth analysis to determine petitioners' income. Petitioners agree with respondent's net worth analysis except...

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