T.C. Memo. 1998-269
UNITED STATES TAX COURT
MICHAEL A. AND KARYN E. SCHMITT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22670-95. Filed July 23, 1998.
Lawrence M. Lebowsky, for petitioners.
Michelle Or, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax in 1990 and 1991 of $24,808 and
$11,800.71, respectively. The petition in this case seeks a
redetermination only of the deficiency for 1991.
The issue for our consideration is whether petitioners had
unreported Schedule C income in taxable year 1991.
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