T.C. Memo. 1998-255
UNITED STATES TAX COURT
NEIL J. CHRISTAL, II & KATHRYN E. CHRISTAL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12793-96. Filed July 13, 1998.
Dana C. Christian and David Prince, for petitioners.
Laurel Robinson and Thomas G. Schleier, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$36,856, an addition to tax under section 6651(a)(1) of $9,193,
and a penalty under section 6662(a) of $7,371 in petitioners'
1992 Federal income tax.1
1 All section references are to the Internal Revenue Code
in effect for the year in issue, and all Rule references are to
(continued...)
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