T.C. Memo. 1998-397
UNITED STATES TAX COURT
SIDNEY DISHAL AND ANNA DISHAL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 687-97. Filed November 10, 1998.
Dan L. Shehi, for petitioners.
Jeremy L. McPherson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined deficiencies in petitioners'
Federal income taxes and penalties as follows:
Accuracy-Related Penalties
Year Deficiency Sec. 6662 (a)
1992 $34,257 $6,851
1993 53,429 10,686
1994 53,432 10,686
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
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