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FREY v. COMMISSIONER

Docket No. 23834-96.

75 T.C.M. 2546 (1998)

T.C. Memo. 1998-226

Richard A. Frey v. Commissioner.

United States Tax Court.

Filed June 29, 1998.

Attorney(s) appearing for the Case

W. Waverly Townes, Louisville, Ky., for the petitioner. Andrew M. Winkler, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax and penalties for fraud as follows:

Year                       Deficiency   Sec. 6663

1990 ...................    $11,998      $ 8,999
1991 ...................     11,803        8,852
1992 ...................     11,225        8,419
1993 ...................     15,769       11,827

The deficiency in income...

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