T.C. Memo. 2004-189
UNITED STATES TAX COURT
KAING CHIN AND HAE KYUNG BAEK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8740-03. Filed August 24, 2004.
Sang I. Lee, for petitioners.
Alan H. Cooper and Lauren Mark, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine respondent’s determinations as to their 1999 Federal
income tax. As to that year, respondent determined in the notice
of deficiency that petitioners were liable for a $154,896
deficiency and a $30,979.20 accuracy-related penalty under
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