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SCHMIDT v. COMMISSIONER

Docket No. 28514-90.

66 T.C.M. 1187 (1993)

T.C. Memo. 1993-506

Robert D. Schmidt and Lucille P. Schmidt v. Commissioner.

United States Tax Court.

Filed November 2, 1993.

Attorney(s) appearing for the Case

Kevin Mark Klemz, 45 S. Seventh St., Minneapolis, Minn., for the petitioners. James E. Schacht, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined deficiencies in petitioners' 1986 and 1987 Federal income tax in the amounts of $45,387.20 and $108,425.56, respectively. Respondent also determined additions to tax under section 6653(a)(1)(A)1 in the amounts of $2,269.36 and $5,421.28 for 1986 and 1987, respectively, and 50 percent of the interest due on the deficiency as redetermined in each year...

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