SCHAEFER v. COMMISSIONER

Docket No. 16784-92.

68 T.C.M. 655 (1994)

T.C. Memo. 1994-444

Paul A. Schaefer and Estate of Joyce F. Schaefer, Deceased, Paul Schaefer, Personal Representative v. Commissioner.

United States Tax Court.

Filed August 31, 1994.


Attorney(s) appearing for the Case

Thomas G. Hodel, 143 Union Blvd., Lakewood, Colo., for the petitioners. Virginia L. Hamilton, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined Federal income tax deficiencies for petitioners'1 1984 and 1985 taxable years in the amounts of $7,668 and $10,475, respectively. Respondent also determined additions to tax under section 6653(a)(1)2 for 1984 and 1985 in the amounts of $383 and $524, respectively. If the section 6653(a)(1) addition is upheld, the addition...

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