Attardo v. Commissioner

SEBASTIAN AND SHARON ATTARDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Attardo v. Commissioner

Docket No. 19732-88

United States Tax Court

T.C. Memo 1991-357; 1991 Tax Ct. Memo LEXIS 406; 62 T.C.M. (CCH) 313; T.C.M. (RIA) 91357;

August 1, 1991, Filed

Decision will be entered under Rule 155.

Bradley J. Davis and Victoria J. Alvarez, for the petitioners.

Steve R. Johnson, for the respondent.

COHEN, Judge.

COHEN

MEMORANDUM OPINION

Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:

Additions to Tax

Sec.

Sec.

Year

Deficiency

6653(a)(1)

6653(a)(2)

1984

$…