T.C. Memo. 1997-383
UNITED STATES TAX COURT
EVA J. MADIGAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20371-94. Filed August 21, 1997.
B. Gray Gibbs, for petitioner.
J. Scot Simpson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined a deficiency of
$20,238 in petitioner's Federal income tax for taxable year 1991.
Respondent further determined that petitioner is liable for
additions to tax under sections 6651(a)1 and 6654 in the amounts
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the year at issue, and
(continued...)
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