WONG v. COMMISSIONER

Docket No. 9821-92.

67 T.C.M. 2911 (1994)

T.C. Memo. 1994-202

Nolan Wong and Angela Wong v. Commissioner.

United States Tax Court.

Filed May 5, 1994.


Attorney(s) appearing for the Case

Robert E. Hunter, 345 Grove St., San Francisco, Calif., for the petitioners. Elaine Sierra, for the respondent.


Memorandum Opinion

RAUM, Judge:

The Commissioner determined the following deficiencies in income tax and additions to tax against petitioners for 1985 and 1986:

                        1985      1986

Deficiency             $32,350   $19,133

Additions to Tax:
  Sec. 6651(a)           8,088     4,783
  Sec. 6653(a)(1)        1,618
  Sec. 6653(a)(1)(A)                 957
  Sec. 6653(a)(2)         1
                    
                    
                    

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