Brown v. Commissioner

KENNETH W. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brown v. Commissioner

Docket No. 903-90

United States Tax Court

T.C. Memo 1992-40; 1992 Tax Ct. Memo LEXIS 46; 63 T.C.M. (CCH) 1866; T.C.M. (RIA) 92040;

January 21, 1992, Filed

Decision will be entered under Rule 155.

Samuel R. McCord and Marion F. Walker, for petitioner.

Alan Friday, for respondent.

FAY, Judge.

FAY

MEMORANDUM OPINION

By statutory notice of deficiency, respondent determined deficiencies in and additions to petitioner's Federal income tax in the following amounts:

Additions to Tax

Year

Deficiency

Sec. 6651(a)(1) 1

Sec.…