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FAWSON v. COMMISSIONER

Docket No. 7705-99.

79 T.C.M. 2208 (2000)

T.C. Memo. 2000-195

Norman H. Fawson and Mary Jane B. Fawson v. Commissioner.

United States Tax Court.

Filed June 28, 2000.

Attorney(s) appearing for the Case

Bruce E. Babcock, for the petitioners. Richard W. Kennedy, for the respondent.

MEMORANDUM OPINION

DEAN, Special Trial Judge.

Respondent issued a notice of deficiency to petitioners for taxable year 1982. In the notice, respondent determined that petitioners were liable for additions to tax for negligence pursuant to section 6653(a)(1)1 of $509.75 and pursuant to section 6653(a)(2) for 50 percent of the interest due on $10,195. Respondent also determined an addition to tax of $2,548.75 for a substantial...

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