United States Tax Court September 22, 1993, Docket Nos. 27682-90, 27684-90, 29100-90 (Cramer v. Commissioner)

lead-opinion

Cohen, Judge:

In these consolidated cases, respondent determined deficiencies in and additions to petitioners’ Federal income taxes as follows:

Richard A. and Alice D. Cramer

Docket No. 27682-90

Additions to tax

Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661

1982 $7,802,334 $390,117 1 $1,950,584

Warren K. and Susi M. Boynton

Docket No.