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BLACKWELL v. COMMISSIONER

Docket Nos. 36235-86, 36236-86.

55 T.C.M. 286 (1988)

T.C. Memo. 1988-87

Larry Blackwell v. Commissioner. Torrence Owens v. Commissioner.

United States Tax Court.

Filed February 29, 1988.

Attorney(s) appearing for the Case

Joseph L. Gibson, Jr., 1511 K St. N.W., Washington, D.C., for the petitioners. Ruud Duval, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner Larry Blackwell's 1985 Federal income tax as follows:

                               Additions to Tax
    Deficiency        § 6653(b)(1)1    § 6653(b)(2)

  $9,046,754.00       $4,523,377.00          *

* 50 percent of the interest due on the underpayment.

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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