T.C. Memo. 1997-281
UNITED STATES TAX COURT
JOAO MONTORO AND NEUZA PAULA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6182-95. Filed June 23, 1997.
Charles L. Steel IV, for petitioners.
Jeanne Gramling, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners' Federal income tax and additions to tax as follows:
Additions to Tax Penalty
Sec. Sec. Sec.
Year Deficiency 6653(a)1 6661 6662
1987 $5,592 $280 $1,398 --
1988 4,604 230 -- --
1990 33,961 -- -- $5,007
1991 96,366 -- -- 17,108
1 Respondent determined that petitioners are liable for an addition to tax for
negligence under sec. 6653(a)(1)(A) for 1987, 50 percent of the interest due on the
underpayment attributable to negligence under sec. 6653(a)(1)(B) for 1987, and an
addition to tax for negligence under sec. 6653(a)(1) for 1988.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011