United States Tax Court September 1, 1987, Docket No. 2139-85. (Janous v. Commissioner)

ELINOR ANN JANOUS, petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Janous v. Commissioner Docket No. 2139-85. United States Tax Court T.C. Memo 1987-443; 1987 Tax Ct. Memo LEXIS 440; 54 T.C.M. (CCH) 405; T.C.M. (RIA) 87443; September 1, 1987. *440 Held: (1) P was taxable on the income received by her in 1982; and (2) P is liable for additions to tax under sec. 6651(a)(1), I.R.C.