United States Tax Court July 19, 2001, No. 3336-95 (MUELLER v. COMMISSIONER)

T.C. Memo. 2001-178

UNITED STATES TAX COURT

CHRISTA KARIN MUELLER, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 3336-95. Filed July 19, 2001.

P and H filed a joint return for 1986. R

determined a deficiency in tax on account of omission

of embezzlement income and gain from liquidation of

corporation, both items attributable to H. R also

determined a sec. 6661, I.R.C.