T.C. Memo. 1998-432
UNITED STATES TAX COURT
JUNG SIK LIM & BOK S. LIM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17433-97. Filed December 10, 1998.
Matthew J. McCann, for petitioners.
Wendy L. Wojewodski, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioners’ 1993 Federal income tax of $8,909. Petitioners
claim an overpayment of their 1993 Federal income tax in the
amount of $4,172. Respondent has conceded all adjustments
determined in the notice of deficiency, and the remaining issue
concerns petitioners’ claim for an overpayment. In order to
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