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WICKERSHAM v. COMMISSIONER

Docket No. 14562-97.

78 T.C.M. 315 (1999)

T.C. Memo. 1999-276

Charles T. Wickersham and Sandra J. Wickersham v. Commissioner.

United States Tax Court.

Filed August 20, 1999.

Attorney(s) appearing for the Case

George W. Connelly, Jr., and Linda S. Paine, for the petitioners. Wanda M. Cohen and R. Scott Shieldes, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $97,899 and a penalty pursuant to section 6663(a) of $73,424 with respect to petitioners' 1989 Federal income tax.1

After concessions,2 the primary issue for decision is whether Charles T. Wickersham (Mr. Wickersham) is liable for the fraud penalty pursuant to section 6663(a). If we so find, we must...

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