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KRISHNA v. COMMISSIONER

Docket No. 19894-95.

73 T.C.M. 2935 (1997)

T.C. Memo. 1997-254

Sita G. and Mangalore Krishna v. Commissioner.

United States Tax Court.

Filed June 9, 1997.

Attorney(s) appearing for the Case

Sita G. Krishna and Mangalore Krishna, pro sese. Mary Ann Amodeo and Steven D. Tillem, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined a deficiency of $22,396 in petitioners' 1991 Federal income tax and an addition to tax pursuant to section 6651(a)(1) of $1,180.

Unless otherwise indicated, all section and Code references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After concessions,

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