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LEVIE v. COMMISSIONER

Docket No. 30411-89.

63 T.C.M. 2798 (1992)

T.C. Memo. 1992-230

Leonard M. Levie v. Commissioner.

United States Tax Court.

Filed April 20, 1992.

Attorney(s) appearing for the Case

Leonard M. Levie, pro se. Ross A. Rowley and Paul G. Topolka, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent by means of a statutory notice of deficiency determined a deficiency in Federal income taxes due from petitioner for 1985 in the amount of $158,064, and additions to tax for fraud under section 6653(b)(1)1 in the amount of $79,032, and section 6653(b)(2) in the amount of 50 percent of the interest due on $145,966, and for substantial understatement of income tax...

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