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 thePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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