Docket No. 1448-94.

72 T.C.M. 1540 (1996)

T.C. Memo. 1996-555

Carl Goudas and Marilyn Goudas v. Commissioner.

United States Tax Court.

Filed December 23, 1996.

Attorney(s) appearing for the Case

Frederick N. Widen and Benjamin J. Ockner, Cleveland, Ohio, for the petitioners. Terry W. Vincent, for the respondent.


BEGHE, Judge:

Respondent determined a deficiency of $230,158 in petitioners' 1988 Federal income tax, and additions to tax of $11,508 and $57,540, respectively, under sections 6653(a) and 6661.1 The deficiency arose from respondent's determination that petitioner2 had a distributive share of $827,968 in the partnership...

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