United States Tax Court March 29, 1989, Docket Nos. 34853-84, 34408-85 (Petzoldt v. Commissioner)

lead-opinion

HAMBLEN, Judge:

Respondent determined deficiencies and additions to tax in petitioner’s Federal income taxes as follows:

Additions to tax

Sec. Sec. Sec.

Year Deficiency 6653(b)(1) 1 6653(b)(2) 6654

1983 $861,136 $430,568 * $52,737

1984 963,717 481,859 ** 60,589

The issues for determination are:

1.