Cheh

UNTE CHEH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cheh

Docket No. 27746-89

United States Tax Court

T.C. Memo 1992-658; 1992 Tax Ct. Memo LEXIS 699; 64 T.C.M. (CCH) 1291;

November 10, 1992, Filed

Decision will be entered under Rule 155.

For Petitioner: Ronald B. Rubin, Terry A. Bauman, and Richard C. Stark.

For Respondent: Lindsey D. Stellwagen.

PARKER

PARKER

MEMORANDUM OPINION

PARKER, Judge: By statutory notice of deficiency dated October 13, 1989, respondent determined a deficiency in petitioner's Federal income tax and additions to tax as follows:

Additions to Tax

Year

Deficiency

Sec.…