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ROEHNING v. COMMISSIONER

Docket No. 24894-86.

57 T.C.M. 978 (1989)

T.C. Memo. 1989-345

Donald H. and Mary Lou Roehning v. Commissioner.

United States Tax Court.

Filed July 19, 1989.

Attorney(s) appearing for the Case

Donald H. Roehning and Mary Lou Roehning, pro se. Mary E. (Betsy) Pierce, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax of $3,768 for the taxable year 1982 and an addition to tax for fraud against petitioner Donald H. Roehning only, which respondent has conceded is inapplicable. In his answer, respondent determined an addition to tax for negligence against both petitioners as an alternative to his fraud allegations. After concessions by the...

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