T.C. Memo. 1996-466 UNITED STATES TAX COURT FRED AND YVONNE MICHAEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15057-94. Filed October 16, 1996. Ted H. Merriam and David A. Sprecace, for petitioners. Richard D. D'Estrada, for respondent. MEMORANDUM OPINION FAY, Judge: By notice of deficiency dated May 23, 1994, respondent determined a deficiency in petitioners' 1991 Federal income tax return in the amount of $21,113 and an addition to tax and a penalty under sections1 6651(a)(1)2 and 6662(a) in the 1All section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011