T.C. Memo. 1995-515
UNITED STATES TAX COURT
LEONARD L. LEIGHTON AND JOYCE S. LEIGHTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21169-93. Filed October 30, 1995.
Leonard L. Leighton, for petitioners.
Stephen C. Coen, for respondent.
MEMORANDUM OPINION
K�RNER, Judge: Respondent determined deficiencies in and
additions to petitioners' Federal income taxes for the years and
in the amounts as follows:
Additions to Tax Under Section
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 6661
1987 $463,497 $23,175 * -- $115,874
1988 6,530 -- -- $327 1,633
*50 percent of the interest due on the deficiency.
All statutory references are to the Internal Revenue Code
in effect for the years in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure, except as
otherwise noted.
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