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 references
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