HILTON v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in and additions to petitioner's individual Federal income tax for calendar year ending December 31, 1981, as follows:

                Additions to tax
                Sec.         Sec.
Deficiency   6653(a)(1)   6653(a)(2)

$53,957.99   $2,697.90        *

* 50 percent of the interest due on $53,957.99.

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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