T.C. Memo. 1996-119
UNITED STATES TAX COURT
CHARLES KADLEC AND LESLEY C. KADLEC, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22506-94. Filed March 12, 1996.
Lisa J. Steele, for petitioners.
Melanie M. Garger, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $50,115
in petitioners’ 1988 Federal income tax. Respondent further
determined an addition to tax pursuant to section 6651(a)(1)1 in
the amount of $12,529.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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