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...)
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