T.C. Memo. 1996-429
UNITED STATES TAX COURT
ARUN AND ASMITA BHATIA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21830-94. Filed September 24, 1996.
Barry L. Gardiner, for petitioners.
Paul N. Schneiderman, for respondent.
MEMORANDUM OPINION
TANNENWALD, Judge: Respondent determined a deficiency in
petitioners' 1987 Federal income tax in the amount of $138,290
plus an addition to tax of $34,573 under section 6661.1
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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