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 former
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011