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STEPIEN v. COMMISSIONER

Docket No. 8161-95.

71 T.C.M. 1688 (1996)

T.C. Memo. 1996-6

Joseph C. Stepien v. Commissioner.

United States Tax Court.

Filed January 11, 1996.

Attorney(s) appearing for the Case

Raymond N. McCabe, Buffalo, N.Y., for the petitioner. Lynne Camillo and Matthew I. Root, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is presently before the Court on respondent's Motion for Partial Summary Judgment.

Respondent seeks a partial summary adjudication that there is an underpayment in petitioner's income tax for the taxable year 1984, and that a portion of such underpayment is attributable to fraud within the meaning of section 6653(b).1 As explained in more detail below, we agree...

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