T.C. Memo. 1997-351
UNITED STATES TAX COURT
OTELIO S. RANDALL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19504-95. Filed July 30, 1997.
Towner Shields Leeper, John Edward Leeper, and Robert I.
White, for petitioner.
Nancy Graml, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
ciencies in, and additions to, petitioner's Federal income tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6654
1991 $68,440 $11,214 $2,228
1992 53,582 6,951 1,087
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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