T.C. Memo. 1997-326
UNITED STATES TAX COURT
TIMOTHY L. AND JANE WILLIAMS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 557-95. Filed July 16, 1997.
Timothy L. Williams, pro se.
Julie M.T. Foster, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax and accuracy-related penalties
for substantial understatements of income tax as follows:1
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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