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MARIA v. COMMISSIONER

Docket No. 1290-92.

68 T.C.M. 1468 (1994)

T.C. Memo. 1994-622

Cyrus T. Santa Maria and Luisa J. Santa Maria v. Commissioner.

United States Tax Court.

Filed December 19, 1994.

Attorney(s) appearing for the Case

Peter S. Buchanan, 170 Columbus Ave., San Francisco, Calif., for the petitioner. Charlotte A. Mitchell, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1987 of $57,038, and additions to tax of: $2,852 under section 6653(a)(1)(A);1 50 percent of the interest due on $57,038 under section 6653(a)(1)(B); and $14,260 under section 6661.

The issues for decision are: (1) Whether section 982 bars the admission of documents submitted by petitioners. We...

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