Stovall v. Commissioner

RAWLIN L. STOVALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Stovall v. Commissioner

Docket No. 1011-77.

United States Tax Court

T.C. Memo 1983-450; 1983 Tax Ct. Memo LEXIS 341; 46 T.C.M. (CCH) 894; T.C.M. (RIA) 83450;

July 28, 1983.

Lorraine Woods, for petitioner.

James D. Harbert and Harmon B. Dow, for respondent.

COHEN

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:* Respondent determined deficiencies in and additions to petitioner's Federal income tax for 1972 and 1973 in the following amounts:

Additions to Tax

Year

Deficiency

Sec. 6651(a) 1

Sec. 6653(a)

1972

$1,386,664

$346,666

$69,33…