T.C. Memo. 1997-396
UNITED STATES TAX COURT
S. BYRNE DOYLE and BARBARA S. DOYLE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8309-96. Filed August 28, 1997.
Mark Clement, for petitioners.
Donna P. Leone, for respondent.
MEMORANDUM OPINION
TANNENWALD, Judge: Respondent determined a deficiency of
$3,199 in petitioners' 1983 Federal income tax, an addition to
tax of $160 under section 6653(a)(1),1 an addition to tax under
1 Unless otherwise indicated, all statutory references are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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