Wong v. Commissioner

NOLAN WONG AND ANGELA WONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Wong v. Commissioner

Docket No. 9821-92

United States Tax Court

T.C. Memo 1994-202; 1994 Tax Ct. Memo LEXIS 202; 67 T.C.M. (CCH) 2911;

May 5, 1994, Filed

Decision will be entered under Rule 155.

For petitioners: Robert E. Hunter

For respondent: Elaine Sierra

RAUM

RAUM

MEMORANDUM OPINION

RAUM, Judge: The Commissioner determined the following deficiencies in income tax and additions to tax against petitioners for 1985 and 1986:

1985

1986

Deficiency

$ 32,350

$ 19,133

Additions to tax:

Sec. 6651(a)

8,088

4,783

Sec. 6653(a)(1)

1,618

Se…