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COLE v. COMMISSIONER

Docket No. 7696-89.

63 T.C.M. 1921 (1992)

T.C. Memo. 1992-51

James W. Cole v. Commissioner.

United States Tax Court.

Filed January 28, 1992.

Attorney(s) appearing for the Case

Earl G. Covington, 1700 W. Loop South, Houston, Tex., for the petitioner. Carol Bingham McClure, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Chief Judge:

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

                                   Addition to tax
Year                  Deficiency    Section 6661

1985 ..............     $ 8,388        $2,097
1986 ..............      11,441         2,860

(Section references are to the Internal Revenue Code...

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