WATERS v. COMMISSIONER

Docket No. 9983-88.

62 T.C.M. 778 (1991)

T.C. Memo. 1991-462

John J. Waters and Jeanne M. Waters v. Commissioner.

United States Tax Court.

Filed September 23, 1991.


Attorney(s) appearing for the Case

Stephen D. Gardner and Michael G. Lefkowitz, 1345 Avenue of the Americas, New York, N.Y. 10105, for the petitioners. Jody Tancer and Laurie B. Kazenoff, for the respondent.


Memorandum Findings of Fact and Opinion

SWIFT, Judge:

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

                                        Sec. 6661
Year                    Deficiency   Addition to Tax1

1982 ................    $14,361         $3,590
1983 ................     20,258          5,065
1984 ................  ...

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