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SRIVASTAVA v. COMMISSIONER

Docket No. 26605-95.

76 T.C.M. 638 (1998)

T.C. Memo. 1998-362

Sudhir P. Srivastava and Elizabeth S. Pascual v. Commissioner.

United States Tax Court.

Filed October 6, 1998.

Attorney(s) appearing for the Case

Michael D. Cropper, Midland, Tex., for the petitioners. W. Mark Scott, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined deficiencies in, and penalties on, the Federal income tax for 1991 and 19921 of Sudhir P. Srivastava (petitioner) and Elizabeth S. Pascual (Pascual) as follows:

                                  Accuracy-Related
Year               Deficiency   Penalty Sec. 6662(a)

1991 ...........   $1,188,920        $237,784...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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