Torney v. Commissioner

RICHARD W. AND LAURIE TORNEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Torney v. Commissioner

Docket No. 7366-91

United States Tax Court

T.C. Memo 1993-385; 1993 Tax Ct. Memo LEXIS 390; 66 T.C.M. (CCH) 493;

August 24, 1993, Filed

Decision will be entered under Rule 155.

For petitioners: P. Gary Ferrero and Michelle Turpin.

For respondents: David L. Miller.

CLAPP

CLAPP

MEMORANDUM FINDINGS OF FACT AND OPINION

CLAPP, Judge: Respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:

Additions to Tax

Year

Sec.

Sec.

Sec.

Sec.

Ended

Deficiency

6653(a)(1)(A)

6…