T.C. Memo. 1997-448
UNITED STATES TAX COURT
DHARMA ENTERPRISES, Petitioner v. COMMISSIONER
OF INTERNAL REVENUE, Respondent
Docket No. 16756-95. Filed September 30, 1997.
Charles W. Tuckman, Richard A. Saffir, and Robert C.
Alexander, for petitioner.
James P. Thurston, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioner's Federal income tax and accuracy-related penalties
under section 6662(a)1 for taxable years ending May 31 as
follows:
1 Unless otherwise indicated, all section and subchapter
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
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