T.C. Memo. 1998-208
UNITED STATES TAX COURT
SHARIF M. AND AMAL BATTIKHI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26471-96. Filed June 16, 1998.
Sharif M. Battikhi and Amal Battikhi, pro se.
Gretchen A. Kindel, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
respondent's motion for summary judgment. For reasons stated
below, we grant respondent's motion.
Respondent determined a deficiency in petitioners' Federal
income tax for 1992 of $8,758 and determined that petitioners are
liable for the accuracy-related penalty for negligence under
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