ENGEL v. COMMISSIONER

Docket No. 27673-89.

66 T.C.M. 378 (1993)

T.C. Memo. 1993-362

George H. Engel and Asanee L. Engel v. Commissioner.

United States Tax Court.

Filed August 18, 1993.


Attorney(s) appearing for the Case

Jeffrey Cole, 321 S. Plymouth Ct., Chicago, IL, for the petitioners.

James R. McCann, Patrick T. Sheehan, and Jonathan P. Decator, for the respondent.


Memorandum Findings of Fact and Opinion

PARKER, Judge:

By statutory notice of deficiency, dated August 29, 1989, respondent determined a deficiency in petitioners' Federal income tax for the year 1985 in the amount of $56,522. Respondent also determined additions to the tax as follows:

Sec. 6653(a)(1)    Sec. 6653(a)(2)   Sec. 6659

   $2,826.10       50% of interest   $16,956.60
                  due on deficiency
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