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MARTIN v. COMMISSIONER

Docket Nos. 23316-83, 31751-83.

51 T.C.M. 403 (1986)

T.C. Memo. 1986-46

Clarence L. Martin and Margaret L. Martin v. Commissioner.

United States Tax Court.

Filed February 3, 1986.

Attorney(s) appearing for the Case

Donald E. Wharton, 1330 21st St., Sacramento, Calif., for the petitioners. Debra Bowe and Steven Mopsick, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1980 and 1981 in the respective amounts of $5,293 and $5,013, additions to tax under section 6653(a)(1) in the respective amounts of $265 and $250.65 and an addition to tax under section 6653(a)(2) for the year 1981 to be based on an underpayment of $5,013. Respondent has also requested that the United States be awarded damages...

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