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SOLIMENE v. COMMISSIONER

Docket No. 1502-74.

44 T.C.M. 321 (1982)

T.C. Memo. 1982-370

Francisco Solimene v. Commissioner.

United States Tax Court.

Filed June 30, 1982.

Attorney(s) appearing for the Case

Moe D. Karash, 206 5th Ave., New York, N.Y. for the petitioner. Jack H. Klinghoffer, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:*

Respondent determined deficiencies in petitioner's Federal income taxes of $265,077.50 for the calendar year 1971, and additions to tax under sections 6651(a), 6653(a) and 6654(a) in the amounts of $66,269.38, $13,253.88, and $8,482.48, respectively.1 The primary issue is whether the respondent acted arbitrarily when he determined that petitioner...

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