T.C. Memo. 1998-91
UNITED STATES TAX COURT
KERN S. AND SOLEDAD D. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27712-96. Filed March 3, 1998.
Kern S. Smith and Soledad D. Smith, pro sese.
Thomas G. Schleier, for Respondent.
MEMORANDUM OPINION
PARR, Judge: Respondent determined a deficiency in
petitioners' Federal income tax for the taxable year 1993 in the
amount of $60,448, an addition to tax of $15,113 under section
6651(a)(1), and a penalty of $12,090 under section 6662(a). All
section references are to the Internal Revenue Code in effect for
the taxable year in issue, and all Rule references are to the Tax
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