T.C. Memo. 1996-217
UNITED STATES TAX COURT
DAN S. AND NANCY J. MITCHELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19785-94. Filed May 6, 1996.
Dan S. Mitchell and Nancy J. Mitchell, pro se.
Bruce W. Wilpon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of $1,435
and $8,883 in petitioners’ Federal income taxes for 1990 and
1991, respectively. Respondent also determined accuracy-related
penalties of $287 and $1,777 under section 6662(a) for those
years. Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
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