T.C. Memo. 1997-98
UNITED STATES TAX COURT
SHERIEL L. SEXCIUS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4087-95. Filed February 25, 1997.
Sheriel L. Sexcius, pro se.
Aretha Jones, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: Respondent determined a deficiency of
$8,671 in petitioner's Federal income taxes for 1990 and an
addition to tax of $1,746 under section 6651(a)(1). In the
answer, respondent asserted that petitioner is liable for a
penalty under section 6662(a), either for negligence under
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