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WHALLEY v. COMMISSIONER

Docket No. 17230-94.

72 T.C.M. 1422 (1996)

T.C. Memo. 1996-533

Barry D. and Suzanne B. Whalley v. Commissioner.

United States Tax Court.

Filed December 2, 1996.

Attorney(s) appearing for the Case

Barry D. Whalley, pro se. Marion Robus, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined deficiencies in, and penalties on, petitioners' Federal income tax for taxable years 1991 and 1992 as follows:

                                           Penalty
Year                        Deficiency   Sec. 6662(a)

1991 ....................    $12,437       $2,487
1992 ....................     13,908        2,782

After concessions...

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