T.C. Memo. 1998-439
UNITED STATES TAX COURT
IMRE AND GIZELLA CZIRAKI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18878-96. Filed December 15, 1998.
Jeffrey R. Matsen and Arlin P. Neser, for petitioners.
Ian Russell and Michael H. Salama, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent, by means of a statutory notice
of deficiency, determined a deficiency in petitioners’ 1992
income tax of $63,874 and a section 6662(a)1 penalty of $12,775.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year under
consideration, and all Rule references are to this Court's Rules
of Practice and Procedure.
Page: 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011