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DOYLE v. COMMISSIONER

Docket No. 8309-96.

74 T.C.M. 452 (1997)

T.C. Memo. 1997-396

S. Byrne Doyle and Barbara S. Doyle v. Commissioner.

United States Tax Court.

Filed August 28, 1997.

Attorney(s) appearing for the Case

Mark Clement, Pittsburgh, Pa., for the petitioners. Donna P. Leone, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $3,199 in petitioners' 1983 Federal income tax, an addition to tax of $160 under section 6653(a)(1),1 an addition to tax under section 6653(a)(2) equal to 50 percent of the interest due on the deficiency, an addition to tax of $960 under section 6659, and increased interest under section 6621(c). After concessions by petitioners, the issue for decision...

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