Roth v. Commissioner

PHILIP ROTH AND LINDA ROTH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Roth v. Commissioner

Docket Nos. 7791-90, 7792-90

United States Tax Court

T.C. Memo 1992-563; 1992 Tax Ct. Memo LEXIS 581; 64 T.C.M. (CCH) 872;

September 23, 1992, Filed

Decision will be entered under Rule 155.

For Petitioners: Michael Louis Minns and Helena Papadopoulos.

For Respondent: Victoria Sherlock.

COLVIN

COLVIN

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge: Respondent determined that petitioner Philip Roth was liable for additions to tax for fraud under sections 6653(b)(1) and (2)1 and 6661 as follows: