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BENNETT v. COMMISSIONER

Docket No. 10081-82.

53 T.C.M. 403 (1987)

T.C. Memo. 1987-148

Robert L. Bennett v. Commissioner.

United States Tax Court.

Filed March 19, 1987.

Attorney(s) appearing for the Case

Robert L. Bennett, pro se, Watertown, N.Y. Louis John Zeller, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $18,665.99 in petitioner's Federal income tax for the taxable year 1977 and an addition to tax for fraud of $9,332.99 under section 6653(b).1 The issues for decision are whether petitioner (1) received constructive dividends in the amounts determined by respondent, and (2) is liable for the addition to tax for fraud under section...

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