Charles W. And Marlene D. Stelly v. Commissioner of Internal Revenue

I

The Stellys appeal the United States Tax Court’s decision assessing a deficiency and penalty against the taxpayers. Based on the frivolous nature of their contentions, we dismiss this appeal and tax double costs and reasonable attorney’s fees against the Stellys.

II

On their 1980 return, the Stellys reported almost $40,000 in wages and $1,847.55 in interest income. They failed, however, to report approximately $2,300 of their inter est income. The IRS issued to the Stellys a notice of the deficiency assessing $948 additional tax due on the interest income.

The Stellys petitioned the Tax Court…