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BREAKELL v. COMMISSIONER

Docket No. 12292-90.

97 T.C. 282 (1991)

WALTER J. BREAKELL, III AND DOROTHY BREAKELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 5, 1991.

Attorney(s) appearing for the Case

John H. Lavelle, for the petitioner.

Elizabeth P. Flores, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $34,346 in petitioners' 1986 Federal income tax together with an addition to tax of $83 under section 6653(a)(1)(A)1 and 50 percent of the interest payable under section 6653(a)(1)(B). After concessions by the parties, the sole issue for decision is the extent to which petitioners understated their tax preference items and therefore their alternative minimum...

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