T.C. Memo. 1997-552
UNITED STATES TAX COURT
ROBERT T. SCHIRLE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13684-95. Filed December 18, 1997.
Gary Kuwada and Steve Mather, for petitioner.
Steven M. Roth and Louise C. Pais, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined the following
deficiencies in, additions to, and penalties on petitioner's
Federal income taxes:
Additions to Tax Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a) 6653(b) 6661 6663(a)
1988 $14,942 --- $12,811 $3,736 ---
1989 39,369 $7,597 --- --- $19,961
1990 120,677 --- --- --- 57,533
1991 128,225 36,402 --- --- 96,169
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