T.C. Memo. 1995-572
UNITED STATES TAX COURT
DON C. RESER AND REBECCA JO RESER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23464-91. Filed November 29, 1995.
Richard H. Tye, for petitioner Don C. Reser.
J. Scott Morris, for petitioner Rebecca Jo Reser.
Joni D. Larson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
K�RNER, Judge: Respondent determined deficiencies in and
additions to petitioners' Federal income taxes as follows:
Additions to Tax Under Section
Year Deficiency 6651(a) 6653(a)(1)/6653(a)(1)(A) 6653(a)(2)/6653(a)(1)(B) 6661
1987 $66,597 $3,330 $3,605 * $16,649
1988 15,326 -- 766 -- 3,832
*Equal to 50 percent of the interest that is computed on the portion of the
underpayment which is attributable to negligence or intentional disregard of rules and
regulations.
All statutory references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
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