T.C. Memo. 1997-416 UNITED STATES TAX COURT NICHOLAS A. AND MARJORIE E. PALEVEDA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 840-96. Filed September 18, 1997. Nicholas A. Paleveda, for petitioners. Clinton M. Fried, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined deficiencies in petitioners' Federal income tax and additions to tax and accuracy-related penalties for the taxable years 1990 and 1991 as follows: Additions Accuracy-Related to Tax Penalties Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1990 $45,861 $11,465 $9,172 1991 47,688 11,922 9,538Page: 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