Denis Brody and Carol Brody - Page 1

                                                                                     










                                 T.C. Memo. 1997-456                                  


                               UNITED STATES TAX COURT                                


                     DENIS BRODY AND CAROL BRODY, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


                  Docket No. 15934-86.           Filed October 8, 1997.               


                  Scott A. Brody, for petitioners.                                    
                  Christopher W. Schoen, for respondent.                              


                                 MEMORANDUM OPINION                                   
                  WHALEN, Judge:  Respondent determined a deficiency of               
             $10,209.09 in petitioners' 1978 income tax, and determined               
             that the entire underpayment for that year is a substantial              
             underpayment attributable to tax-motivated transactions                  
             with the result that the annual rate of interest is 120                  
             percent of the underpayment rate, pursuant to former                     





Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011