Court of Appeals for the Eleventh Circuit October 11, 1983, No. 82-8363 (Cates v. Commissioner)

ALLGOOD, District Judge:

This appeal is from a decision of the United States Tax Court1 holding that the appellants/taxpayers (taxpayers) had realized short term capital gains from the sale of their stock options in Metro “400,” Inc. (Metro) and that taxpayers were liable for a 5 percent addition to tax pursuant to Section 6653(a) of the Internal Revenue Code of 1954 [26 U.S.C. 6653(a)].