T.C. Memo. 1997-301
UNITED STATES TAX COURT
FRED AND MARY GILLETTE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1423-96. Filed June 30, 1997.
Fred Gillette and Mary Gillette, pro sese.
Mark A. Weiner, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: By notice dated December 6, 1995, respondent
determined a deficiency in petitioners' 1992 Federal income tax
of $40,513 and an accuracy-related penalty of $8,103. After
concessions, the issue we must decide is whether petitioners,
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