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TOMASSO v. COMMISSIONER

Docket No. 26320-89.

61 T.C.M. 2416 (1991)

T.C. Memo. 1991-173

George A. Tomasso v. Commissioner.

United States Tax Court.

Filed April 16, 1991.

Attorney(s) appearing for the Case

Kenneth E. Werner and Thomas R. Webb, Cityplace, Hartford, Conn., for the petitioner. John D. Steele, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Special Trial Judge:

Respondent determined a deficiency for the taxable year 1978 in the amount of $135,470.10. Respondent further determined that increased interest was due under section 6621(c)1 (formerly section 6621(d)) for a substantial understatement attributable to a tax-motivated transaction. A timely petition was filed.

This case is before the Court on respondent...

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