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TELLER v. COMMISSIONER

Docket No. 20317-88.

64 T.C.M. 166 (1992)

T.C. Memo. 1992-402

Howard S. Teller and Mei-Li Teller v. Commissioner.

United States Tax Court.

Filed July 15, 1992.

Attorney(s) appearing for the Case

Robert E. Kolek and Daniel L. Kraus, 55 E. Monroe St., Chicago, Ill., for the petitioners. Vijay S. Rajan and William T. Derick, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined a $616,498 income tax deficiency for petitioners' 1983 taxable year. Respondent also determined additions to tax of $30,825 under section 6653(a)(1)1 and $154,125 under section 6661. If section 6653(a)(1) is applicable, then section 6653(a)(2) would also be applicable requiring, pursuant to respondent...

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