T.C. Memo. 1996-325 UNITED STATES TAX COURT R. EDWIN BROWN AND WINSOME S. BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7462-94. Filed July 17, 1996. Rex L. Sturm, for petitioners. Lindsey D. Stellwagen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined a deficiency in petitioners’ Federal income tax for the taxable year 1990 in the amount of $179,597 and an accuracy-related penalty under section 6662(a)1 in the amount of $35,919. 1All section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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