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KRIZER v. COMMISSIONER

Docket No. 28194-89.

62 T.C.M. 1598 (1991)

T.C. Memo. 1991-638

John C. and Elizabeth L. Krizer v. Commissioner.

United States Tax Court.

Filed December 23, 1991.

Attorney(s) appearing for the Case

R. Dow Bonnell, 1518 S. Cheyenne, Tulsa, Okla., for the petitioners. Donald E. Edwards and Nancy S. Vozar, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3)1 and Rule 180 et seq.

In a notice of deficiency, respondent determined for 1985 an addition to tax under section 6661(a) in the count of $4,338 for substantial understatement of income tax. Prior to issuance of the notice of deficiency, petitioners agreed to an income tax deficiency of $17,911 for 1985. Of this deficiency...

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