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SPEAR v. COMMISSIONER

Docket No. 3276-87.

91 T.C. 984 (1988)

LEON SPEAR AND JEANETTE SPEAR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 6, 1988.

Attorney(s) appearing for the Case

Gordon F. Moore II and George J. Anderson, for the petitioners.

James C. Fee, Jr., for the respondent.

OPINION

WILLIAMS, Judge:

This case is before us on petitioners' motion for partial summary judgment. The Commissioner determined deficiencies in petitioners' Federal income tax and additions to tax for fraud for the taxable years 1975, 1976, and 1977 as follows:

                                 Sec. 6653(b)1
    Year     Deficiency     addition to tax

    1975     $51,271.70...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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