SCHULMAN v. COMMISSIONER

Docket No. 12099-91.

68 T.C.M. 797 (1994)

T.C. Memo. 1994-473

Marsha G. Schulman v. Commissioner.

United States Tax Court.

Filed September 28, 1994.


Attorney(s) appearing for the Case

Herbert M. Gannet, for the petitioner. Caroline Ades-Pierri, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined a $225,337 deficiency in petitioner's 1982 income tax. Respondent also determined additions to tax for 1982 of $11,267 for negligence under section 6653(a)(1), 50 percent of the interest due on the underpayment under section 6653(a)(2), and $56,334 for substantial understatement of income tax under section 6661.

The sole issue for decision is whether petitioner qualifies...

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