Kenney v. Commissioner

JOHN F. AND JACQUELYN J. KENNEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kenney v. Commissioner

Docket No. 47766-86

United States Tax Court

T.C. Memo 1993-108; 1993 Tax Ct. Memo LEXIS 128; 65 T.C.M. (CCH) 2152;

March 25, 1993, Filed

For petitioners: Scott Kauffman and Barnet Resnick.

For respondent: Kathryn K. Vetter.

RUWE

RUWE

MEMORANDUM OPINION

RUWE, Judge: Respondent determined a deficiency and additions to tax in petitioners' 1982 Federal income taxes as follows:

Additions to Tax

Deficiency

Sec. 6651

Sec. 6653(a)(1)

Sec. 6653(a)(2)

Sec. 6659

Sec. 6661

$ 64,753

$ 3,572

$ 3,587

50 percent of

$…