T.C. Memo. 1996-466
UNITED STATES TAX COURT
FRED AND YVONNE MICHAEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15057-94. Filed October 16, 1996.
Ted H. Merriam and David A. Sprecace, for petitioners.
Richard D. D'Estrada, for respondent.
MEMORANDUM OPINION
FAY, Judge: By notice of deficiency dated May 23, 1994,
respondent determined a deficiency in petitioners' 1991 Federal
income tax return in the amount of $21,113 and an addition to tax
and a penalty under sections1 6651(a)(1)2 and 6662(a) in the
1All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
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