T.C. Memo. 1995-519 UNITED STATES TAX COURT THOMAS L. HOBART, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25649-93. Filed October 30, 1995. Gregory Daniel Smith, for petitioner. Linda J. Wise, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined a deficiency in the amount of $132,675 in petitioner's Federal income tax for 1988 and an addition to tax pursuant to section 6653(b)(1) in the amount of $101,783. Respondent asserted the delinquency and negligence additions to tax under sections 6651(a)(1) and 6653(a)(1), respectively, in the alternative to the fraud addition to tax. Unless otherwise noted, all section referencesPage: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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