T.C. Memo. 2000-268
UNITED STATES TAX COURT
BARRY AND PENNY KNELMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8397-99. Filed August 24, 2000.
Barry and Penny Knelman, pro sese.
Erica Y. Wu, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$11,790 and an accuracy-related penalty of $2,358 on petitioners’
1994 Federal income tax. After concessions,1 the issues for
1 In the notice of deficiency, respondent determined that
petitioners had underreported their income by $17,753. After
respondent conceded $3,198, petitioners stipulated that they had
received but failed to report $14,555 of operating income from
(continued...)
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