T.C. Memo. 2000-155
UNITED STATES TAX COURT
JAMES L. AND EVA J. DOWNS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1991-99. Filed May 10, 2000.
James L. Downs, pro se.
Rodney J. Bartlett, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: Respondent issued a notice
of deficiency to petitioners for the taxable years 1982 and 1983.
In the notice, respondent determined that petitioners were liable
for additions to tax for negligence pursuant to section
6653(a)(1)1 of $464 and $8 for 1982 and 1983, respectively, and
under section 6653(a)(2) for 50 percent of the interest due on
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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