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OSBORNE v. COMMISSIONER

Docket Nos. 8455-93, 14846-93.

69 T.C.M. 1895 (1995)

T.C. Memo. 1995-71

Richard A. Osborne v. Commissioner. Peter L. Dawson v. Commissioner.

United States Tax Court.

Filed February 14, 1995.

Attorney(s) appearing for the Case

F. Brook Voght, J. Bradford Anwyll, Kevin L. Kenworthy, and Michael E. Baillif, for the petitioner in Docket No. 8455-93. Janet Altman Spragens, Andrew J. Weinstein (specially recognized), and David P. Korteling (specially recognized), for the petitioner in Docket No. 14846-93. Leonard T. Provenzale, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:

These consolidated cases were assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1

By notice of deficiency dated February 5, 1993, respondent determined a deficiency in petitioner Richard A. Osborne's (Osborne) 1989 Federal income tax in the amount of $5,299 and additions to tax pursuant to sections 6653(a)(1) and...

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