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HENRY v. COMMISSIONER

Docket Nos. 27188-91, 1987-92.

73 T.C.M. 1769 (1997)

T.C. Memo. 1997-29

Albert J. Henry v. Commissioner. Mary Henry v. Commissioner.

United States Tax Court.

Filed January 16, 1997.

Attorney(s) appearing for the Case

Timothy M. Hughes, Charles F. Gibbs, and William G. Cavanaugh, New York, N.Y., for the petitioners. June Y. Bass and Valerie N. Larson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $2,099,534 and additions to tax pursuant to sections 6653(a)(1)1 and 6661 in the amounts of $104,976.70 and $524,883.50, respectively.

The issues remaining for our consideration concern whether petitioners are liable for additions to tax under section 6653(a)(1) and (2) and...

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