HOWARD v. COMMISSIONER

Docket No. 2169-85.

55 T.C.M. 575 (1988)

T.C. Memo. 1988-148

William W. and Marion E. Howard v. Commissioner.

United States Tax Court.

Filed April 11, 1988.


Attorney(s) appearing for the Case

Randy C. Irvine, Lukenville Enterprises, Sacramento, Calif., for the petitioners. Janice M. Fallman, for the respondent.


Memorandum Opinion

PARR, Judge:

By his notice of deficiency dated October 26, 1984, respondent determined a deficiency in petitioners' income tax for 1980 in the amount of $11,165.75 and an addition to tax under section 6651(a)1 in the amount of $1,570.19. By amended answer respondent alleges an increased deficiency of $700 and an increased section 6651(a) addition of $175.

After mutual concessions, the issue for decision...

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