BAILEY v. COMMISSIONER

Memorandum Opinion

KÖRNER, Judge:

For the calendar year 1985, respondent determined a deficiency of income tax in the amount of $223,396 against petitioner, together with additions to tax as follows:

  Section 6651(a)(1)1 .............. $55,849
  Section 6653(a)(1) ...............  11,170
  Section 6653(a)(2) ...............    *
  Section 6654 .....................  12,801
  Section 6661 ..................

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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