T.C. Memo. 1998-259
UNITED STATES TAX COURT
STEVEN J. AND JEAN L. LIDDANE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15738-96. Filed July 14, 1998.
Steven J. and Jean L. Liddane, pro sese.
Gerald W. Douglas, for respondent.
MEMORANDUM OPINION
BEGHE, Judge: This case is before the Court on cross-
motions for summary judgment under Rule 1211 and respondent's
motion to impose a penalty under section 6673. Respondent
determined a deficiency of $10,613 in petitioners' 1992 Federal
1 All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the year in issue.
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