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MIRAVALLE v. COMMISSIONER

Docket No. 7251-93.

70 T.C.M. 220 (1995)

T.C. Memo. 1995-349

Donald J. and Lillian Joy Miravalle v. Commissioner.

United States Tax Court.

Filed July 31, 1995.

Attorney(s) appearing for the Case

Donald J. and Lillian Joy Miravalle, pro se. Howard P. Levine, for the respondent.

MEMORANDUM FINDING OF FACTS AND OPINION

GERBER, Judge:

Respondent determined Federal income tax deficiencies for petitioners' 1988 and 1989 tax years in the amounts of $1,082.90 and $23,508.58, respectively. Respondent also determined additions to tax under section 6653(a)1 for 1988 and section 6662(a) for 1989 in the amounts of $54 and $4,700, respectively. After concessions by the parties, the issues2

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