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WILLIAMS v. COMMISSIONER

Docket No. 36698-87.

94 T.C. 464 (1990)

LLOYD E. WILLIAMS, JR. AND MILDRED A. WILLIAMS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 21, 1990.

Attorney(s) appearing for the Case

J. Gordon Hansen and Stuart A. Fredman, for the petitioners.*

David L. Zoss, Lewis J. Fernandez, and James C. Lanning, for the respondent.

OPINION

CLAPP, Judge:

Respondent determined a $29,015 deficiency in petitioners' Federal income tax and a $7,254 addition to tax under section 6661 for the year 1983. In his amended answer, respondent increased the deficiency to $61,011.50 and conceded that section 6661 is not applicable. All section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court...

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