T.C. Memo. 1998-113
UNITED STATES TAX COURT
ROLF E. POLENTARUTTI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17117-95. Filed March 19, 1998.
Rolf Polentarutti, pro se.
James F. Kearney, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioner had a
deficiency in income tax for 1989 of $78,123, and was liable for
an addition to tax of $3,906 under section 6651(a)(1) for failure
to file timely and an accuracy-related penalty of $15,625 under
section 6662(a) for negligence.
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