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DiJOHN v. COMMISSIONER

Docket No. 5778-88.

62 T.C.M. 868 (1991)

T.C. Memo. 1991-484

Anthony DiJohn and Gerri DiJohn v. Commissioner.

United States Tax Court.

Filed September 30, 1991.

Attorney(s) appearing for the Case

Michael K. McBeath, for the petitioners. J. Michal Nathan, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax liability for 1981 in the amount of $5,216. Respondent also determined additions to tax under section 6653(a)(1)1 in the amount of $261 and under section 6653(a)(2) in an amount to be determined (50 percent of the interest due on the portion of the underpayment attributable to negligence or intentional disregard...

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