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BENNETT v. COMMISSIONER

Docket No. 21163-94.

73 T.C.M. 2389 (1997)

T.C. Memo. 1997-145

Terence M. Bennett v. Commissioner.

United States Tax Court.

Filed March 19, 1997.

Attorney(s) appearing for the Case

Peter D. Anderson, Manchester, N.H., Steven M. Burke, and Kelly A. Ayotte, for the petitioner. Ronald F. Hood, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $778,866 in petitioner's 1988 Federal income tax. Respondent further determined additions to tax pursuant to sections 6653(a)(1)1 and 6661 in the amounts of $38,943 and $194,717, respectively.

The issues for decision are: (1) Whether respondent fraudulently induced petitioner to execute a Form 872 (Consent to Extend the Time to...

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