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MICHAEL v. COMMISSIONER

Docket No. 15057-94.

72 T.C.M. 1031 (1996)

T.C. Memo. 1996-466

Fred and Yvonne Michael v. Commissioner.

United States Tax Court.

Filed October 16, 1996.

Attorney(s) appearing for the Case

Ted H. Merriam, Denver, Colo., and David A. Sprecace, for the petitioners. Richard D. D'Estrada, for the respondent.

MEMORANDUM OPINION

FAY, Judge:

By notice of deficiency dated May 23, 1994, respondent determined a deficiency in petitioners' 1991 Federal income tax return in the amount of $21,113 and an addition to tax and a penalty under sections1 6651(a)(1)2 and 6662(a) in the amounts of $3,790 and $2,903, respectively. After concessions, the sole issue for decision is whether petitioners are entitled to an interest...

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