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RADABAUGH v. COMMISSIONER

Docket Nos. 5798-90, 5825-90, 5826-90.

64 T.C.M. 910 (1992)

T.C. Memo. 1992-572

John C. Radabaugh, Jr., et al. v. Commissioner.

United States Tax Court.

Filed September 24, 1992.

Attorney(s) appearing for the Case

John R. Wanick, 1109 Adams St., Toledo, Ohio, for the petitioners. Eric M. Nemeth, for respondent.

Memorandum Findings of Fact and Opinion

BEGHE, Judge:

Petitioners2 and respondent reached agreements regarding deficiencies in petitioners' Federal income taxes for the taxable years 1980 through 1985, but petitioners did not agree that they were liable for any additions to tax. After each petitioner executed a Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment (Form 870...

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