T.C. Memo. 1997-71
UNITED STATES TAX COURT
THOMAS B. DRUMMOND, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16958-94. Filed February 10, 1997.
William F. Krebs and Mark E. Kellogg, for petitioner.
Susan T. Mosley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following
deficiencies in, additions to, and accuracy-related penalties on
petitioner's Federal income tax:
Additions to Tax Accuracy-Related Penalties
Year Deficiency Sec. 6651(a)(1)1 Sec. 6662(a)
1989 $23,141.00 $1,053.80 $5,544.00
1990 30,954.00 7,738.47 5,340.60
1991 25,657.00 -- 4,778.20
1 All section references are to the Internal Revenue Code (Code)
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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