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SIVIC v. COMMISSIONER

Docket No. 18197-90.

65 T.C.M. 1906 (1993)

T.C. Memo. 1993-54

Thomas M. Sivic and Adriana J. Sivic v. Commissioner.

United States Tax Court.

Filed February 18, 1993.

Attorney(s) appearing for the Case

Angelo F. Lonardo, 526 Superior Ave. E., Cleveland, Ohio, and Leonard W. Yelsky, 1050 Leader Bldg., Cleveland, Ohio, for the petitioners. Mario J. Fazio, for the respondent.

Memorandum Opinion

BEGHE, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Year                              Deficiency

1981 ..........................   $15,890.72
1982 ..........................       237.00

Respondent also determined that petitioners are liable for increased interest under section 6621(c) (formerly sec. 6621(d)) for the taxable year 1981.

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