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MONTANO v. COMMISSIONER

Docket No. 19494-83.

51 T.C.M. 1004 (1986)

T.C. Memo. 1986-192

Robert Montano v. Commissioner.

United States Tax Court.

Filed May 14, 1986.

Attorney(s) appearing for the Case

Robert Montano, pro se. Steven Mather and Harry Morton Asch, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1978 in the amount of $21,523.00 and an addition to tax under section 6653(b)1 in the amount of $10,322.94. After concessions, the sole issue for decision is whether petitioner is liable for the addition to tax under section 6653(b).

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