T.C. Memo. 1998-320
UNITED STATES TAX COURT
NEWBY'S PLASTERING, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26799-96. Filed September 8, 1998.
Helen L. Simpson, for petitioner.
Kay Hill, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioner petitioned the Court to redetermine
respondent's determination of the following additions to its 1989
Federal income tax: A $37,270 addition under section 6651(a)(1),
a $42,954 addition under section 6651(a)(2), and a $10,333
addition under section 6655. We decide sua sponte whether we
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