Warner v. Commissioner

MARVIN L. WARNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Warner v. Commissioner

Docket No. 5638-90

United States Tax Court

T.C. Memo 1993-235; 1993 Tax Ct. Memo LEXIS 233; 65 T.C.M. (CCH) 2802;

May 25, 1993, Filed

Decision will be entered under Rule 155.

For petitioner: Scott Alan Orth, Marvin C. Gutter, Richard A. Josepher, and Thomas Ruffin III.

For respondent: Nancy B. Herbert.

COHEN

COHEN

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge: Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

Additions to Tax

Year

Deficiency

Sec.…