T.C. Memo. 1997-162
UNITED STATES TAX COURT
CORDES FINANCE CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27258-93. Filed April 1, 1997.
O. Christopher Meyers, for petitioner.
Gary Bloom, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge: Respondent determined the following
deficiency and penalties with respect to petitioner's 1990
taxable year:
Penalties
Deficiency Sec. 6662(a) Sec. 6663(a)
$1,530,128 $303,025.86 $32,726.25
All section references are to the Internal Revenue Code
as amended and in effect during 1990. All Rule references
are to the Tax Court Rules of Practice and Procedure.
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