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WHITEHEAD v. COMMISSIONER

Docket No. 33317-87.

62 T.C.M. 758 (1991)

T.C. Memo. 1991-455

Eugene H. and Theresa H. Whitehead v. Commissioner.

United States Tax Court.

Filed September 19, 1991.

Attorney(s) appearing for the Case

Joseph F. Moore, for the petitioners. Philip J. Starr and Margaret R. Reichenberg, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

                                    Additions to Tax
Year                   Deficiency     Sec. 6653(a)1

1979 ...............    $ 6,256          $  313
1980 ...............     31,902           1,595

After mutual concessions...

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