T.C. Memo. 1997-456 UNITED STATES TAX COURT DENIS BRODY AND CAROL BRODY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15934-86. Filed October 8, 1997. Scott A. Brody, for petitioners. Christopher W. Schoen, for respondent. MEMORANDUM OPINION WHALEN, Judge: Respondent determined a deficiency of $10,209.09 in petitioners' 1978 income tax, and determined that the entire underpayment for that year is a substantial underpayment attributable to tax-motivated transactions with the result that the annual rate of interest is 120 percent of the underpayment rate, pursuant to formerPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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