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FRENCH v. COMMISSIONER

Docket No. 3265-94.

71 T.C.M. 1956 (1996)

T.C. Memo. 1996-38

Anna Ruth French v. Commissioner.

United States Tax Court.

Filed February 1, 1996.

Attorney(s) appearing for the Case

Jerold K. Nussbaum, Annapolis, Md., for the petitioner. Helen F. Rogers, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for taxable year 1986 in the amount of $123,862. Respondent further determined that petitioner is liable for an addition to tax in the amount of $12,386 pursuant to section 66611 for a substantial understatement of income tax. The issues for decision are:

(1) Whether petitioner qualifies for innocent...

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