T.C. Memo. 1995-477
UNITED STATES TAX COURT
JULIUS AND HANAN DIBSY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16466-93. Filed October 4, 1995.
Julius Dibsy, pro se.
Roy Wulf, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioners' 1989 Federal income tax of $34,079 and additions to
tax under sections 66541 and 6662(a) in the amounts of $191 and
$6,816, respectively. The issues for our consideration are: (1)
1 All section references are to the Internal Revenue Code in
effect for the taxable year under consideration, and all Rule
references are to this Court's Rules of Practice and Procedure,
unless otherwise indicated.
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