Nicolaisen v. Commissioner

FREDERICK C. and LINDA S. NICOLAISEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Nicolaisen v. Commissioner

Docket No. 12033-81.

United States Tax Court

T.C. Memo 1985-120; 1985 Tax Ct. Memo LEXIS 512; 49 T.C.M. (CCH) 977; T.C.M. (RIA) 85120;

March 20, 1985.

Anthony F. Mercurio, for the petitioners.

David W. Johnson, for the respondent.

FAY

MEMORANDUM OPINION

FAY, Judge:* With respect to petitioners' 1977 Federal income tax, respondent determined a deficiency of $5,813.00 and an addition to tax of $290.65 under section 6653(a) 1, 2. After concessions by both parties, the remaining…