LEVIEN v. COMMISSIONER

Docket No. 9006-90.

103 T.C. 120 (1994)

FRANCIS LEVIEN AND JANICE LEVIEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 2, 1994.


Attorney(s) appearing for the Case

Richard P. Swanson and Marc D. Teitelbaum, for petitioners.

Bruce Wilpon and Patricia Beary, for respondent.


OPINION

RUWE, Judge:

Respondent determined deficiencies, additions to tax, and additional interest against petitioners as follows:

                        Additions to      Additional interest
   Year    Deficiency    tax sec. 6659        sec. 6621(c)

   1983    $89,609        $26,883         120% of the interest
                                            due on $89,609
   1984     68,210...

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