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LIGGIO v. COMMISSIONER

Docket No. 42999-85.

66 T.C.M. 732 (1993)

T.C. Memo. 1993-426

Anthony W. Liggio and Maria Elena Liggio v. Commissioner.

United States Tax Court.

Filed September 14, 1993.

Attorney(s) appearing for the Case

Anthony W. Liggio, pro se. Edward P. Guttenmacher and Jerome S. Richman, for the petitioner. Maria Elena Liggio. Kathleen L. Donohue, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income taxes for 1981 and 1982 as follows:

                                                         Additions to Tax
                                                   ----------------------------
Year                                  Deficiency   Sec. 6651(a)(1)   Sec. 6659

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