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KENT v. COMMISSIONER

Docket No. 2361-83.

51 T.C.M. 808 (1986)

T.C. Memo. 1986-139

J. Mark Kent and Janice M. Kent v. Commissioner.

United States Tax Court.

Filed April 10, 1986.

Attorney(s) appearing for the Case

Sidney Soltz, for the petitioners. Theresa E. Mitchell, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in the Federal income tax liability of petitioners for the calendar year 1980 in the amount of $301,530 and an addition to tax under section 6653(b)1 in the amount of $150,765. The deficiency is based upon respondent's contention that petitioner J. Mark Kent (Kent) received unreported income during the year in the amount of $616,740 from...

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