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LIVELY v. COMMISSIONER

Docket No. 29701-89.

63 T.C.M. 1782 (1992)

T.C. Memo. 1992-23

Dwain Lively and Marie Lively v. Commissioner.

United States Tax Court.

Filed January 13, 1992.

Attorney(s) appearing for the Case

Michael J. Abramovitz, for the petitioners. James Gehres, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1985 and 1986 in the amounts of $216,852 and $14,909, respectively, additions to tax for fraud under section 6653(b)(1)1 and (b)(1)(A) in the amounts of $108,426 and $8,534, respectively, and additions to tax for substantial understatement under section 6661 in the respective amounts...

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