STRICKLAND v. COMMISSIONER

Docket No. 2464-92.

67 T.C.M. 1927 (1994)

T.C. Memo. 1994-5

Steven D. Strickland and Doris K. Strickland v. Commissioner.

United States Tax Court.

Filed January 6, 1994.


Attorney(s) appearing for the Case

William E. Frantz, 6100 Lake Forrest Dr., N.W., Atlanta, Ga., for the petitioners. Larry D. Anderson, for the respondent.


Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency in, and additions to, petitioners' joint Federal income tax liability as follows:

                       Additions to Tax — Sections
                       6653       6653
Year   Deficiency   (b)(1)(A)   (b)(1)(B)    6661

1986     $7,417       $5,563        *       $1,854

* 50 percent of...

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