United States Tax Court September 6, 1995, Docket Nos. 21592-93, 21594-93. (Silverman v. Commissioner)

lead-opinion

OPINION

Raum, Judge:

The Commissioner determined deficiencies in income taxes and an increased rate of interest on those deficiencies as follows:

Docket No. 21594-93

Increased interest

Year Deficiency sec. 6621(c)1

1975 $31,781 120% of interest due on $20,781

1976 51,979 120% of interest due on $50,356

1977 3,101 120% of interest due on $3,101

Docket No.