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JOHNSTON v. COMMISSIONER

Dkt. No. 3011-02.

87 T.C.M. 1256 (2004)

T.C. Memo. 2004-107

William H. Johnston and Nancy S. Johnston v. Commissioner.

United States Tax Court.

Filed April 23, 2004.

Attorney(s) appearing for the Case

William H. Johnston and Nancy S. Johnston, pro sese.

David B. Mora, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

By separate notices of deficiency, respondent determined deficiencies in each petitioner's Federal income taxes in the amounts of $2,111 for 1994, $5,563 for 1996, and $2,126 for 1997.1 Respondent also determined that each petitioner is liable for additions to tax for failure to file under section 6651(a)(1) of $100 for 1994 and $120 for 1997,2

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