HOBART v. COMMISSIONER

Docket No. 25649-93.

70 T.C.M. 1117 (1995)

T.C. Memo. 1995-517

Thomas L. Hobart v. Commissioner.

United States Tax Court.

Filed October 30, 1995.


Attorney(s) appearing for the Case

Gregory Daniel Smith, Pensacola, Fla., for the petitioner. Linda J. Wise, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined a deficiency in the amount of $132,675 in petitioner's Federal income tax for 1988 and an addition to tax pursuant to section 6653(b)(1) in the amount of $101,783. Respondent asserted the delinquency and negligence additions to tax under sections 6651(a)(1) and 6653(a)(1), respectively, in the alternative to the fraud addition to tax. Unless otherwise noted, all section references...

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