T.C. Memo. 1998-191
UNITED STATES TAX COURT
ERNEST R. INFELISE AND ANN INFELISE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15207-96. Filed May 26, 1998.
Robert I. Ury, Edward A. Snyder, and Richard C. Gering, for
petitioners.
Donna C. Hansberry and Robert T. Little, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: On April 12, 1996, respondent issued a notice
of deficiency to Ernest and Ann Infelise. In the notice,
respondent determined the following deficiencies in and additions
to petitioners' Federal income tax:
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