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
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