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SMITH v. COMMISSIONER

Docket Nos. 48306-86, 309-87.

93 T.C. 378 (1989)

DEAN B. SMITH AND IRMA SMITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT JAMES KARR AND NANCY L. KARR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1989.

Attorney(s) appearing for the Case

Dennis N. Brager and Jackson D. Hamilton, for the petitioners.

Debra K. Estrem, for the respondent.

SUPPLEMENTAL OPINION

COHEN, Judge:

In Smith v. Commissioner, 91 T.C. 733 (1988), we sustained, in part, respondent's disallowance of certain deductions claimed by partnerships in which petitioners were partners. We held that petitioners were liable for additions to income tax under section 6661 and additional interest under section 6621(c). We directed that decisions...

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