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ARMSTRONG v. COMMISSIONER

Docket No. 19120-87.

59 T.C.M. 632 (1990)

T.C. Memo. 1990-247

Dale D. Armstrong and Anne D. Armstrong v. Commissioner.

United States Tax Court.

Filed May 22, 1990.

Attorney(s) appearing for the Case

Robert E. Kovacevich, for the petitioners. Milton J. Carter, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

In his notice of deficiency, respondent determined that petitioners were liable for a deficiency of $535,092 for tax year 1980 and an addition to tax of $267,546 under section 6653(b).1 Respondent subsequently adjusted his notice of deficiency to reflect a deficiency of $441,030.54 and an addition to tax under section 6653(b) of $220,515.27.

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