Mosteller v. Commissioner

DAVID F. MOSTELLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Mosteller v. Commissioner

Docket No. 15361-81.

United States Tax Court

T.C. Memo 1986-505; 1986 Tax Ct. Memo LEXIS 99; 52 T.C.M. (CCH) 758; T.C.M. (RIA) 86505;

October 7, 1986.

Gerald T. Zerkin, for the petitioner.

John C. McDougal, for the respondent.

PARKER

MEMORANDUM FINDINGS OF FACT AND OPINION

PARKER, Judge: Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:

Sec. 6653(b) 1

Year

Deficiency

Addition

1976

$10,184

$5,092

1977

44,128

22,064

After concessions by both parties, 2 the issues…