T.C. Memo. 1995-536
UNITED STATES TAX COURT
EVERT E. AND EVA F. BERGLUND, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25489-91. Filed November 13, 1995.
Evert E. Berglund, pro se.
Diane L. Worland, for respondent.
MEMORANDUM OPINION
HAMBLEN, Chief Judge: Respondent determined deficiencies
in, and additions to, petitioners' Federal income tax for the
taxable years 1986, 1987, and 1988 as follows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1986 $85,726.45 $4,286.32 * $21,431.61
1987 3,596.50 --- --- ---
1988 2,396.13 --- --- ---
150 percent of the statutory interest due on the amount of the
deficiency attributable to negligence.
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