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
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