T.C. Memo. 1996-86
UNITED STATES TAX COURT
ROBERT G. LESLIE AND MARILYN B. LESLIE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9814-87. Filed February 28, 1996.
Elliott H. Kajan and Steve Mather, for petitioners.
Roger L. Kave, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge: By notice of deficiency dated February 20,
1987, respondent determined deficiencies in petitioners' Federal
income taxes and additions to tax and increased interest as
follows:
Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec.
Year Deficiency 6621(d) 6653(a)(1) 6653(a)(2) 6661
1980 $1,064,080 1 $53,204 -- --
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