T.C. Memo. 1998-234
UNITED STATES TAX COURT
JORGE V. AND CAROL A. GEAGA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13972-97. Filed July 1, 1998.
Jorge V. Geaga, pro se.
Roger P. Law, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: Respondent determined a deficiency of
$14,173 in petitioners' Federal income taxes for 1995 and a
penalty of $2,835 under section 6662(a). All section references
are to the Internal Revenue Code in effect for the year in issue,
unless otherwise indicated. The issue for decision is whether
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