T.C. Memo. 2005-244
UNITED STATES TAX COURT
ERNEST I. KORCHAK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22105-03. Filed October 18, 2005.
Robert T. Connors, for petitioner.
James Brian Urie and Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: Respondent determined additions to
petitioner’s Federal income tax for 1982 of $7,019.40 under
section 6653(a)(1),1 of an amount equal to 50 percent of the
interest due on a $140,388 underpayment under section
1All 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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