T.C. Memo. 1996-162
UNITED STATES TAX COURT
MARK MASSINGILL AND INDRA MASSINGILL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19193-94. Filed March 28, 1996.
Mark and Indra Massingill, pro sese.
David W. Sorenson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $11,006 deficiency
in petitioners’ 1990 Federal income tax. Respondent also
determined an addition to tax under section 6651(a)(1)1 of $1,917
and an accuracy-related penalty under section 6662(a) of $1,390.
1 All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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