T.C. Memo. 1998-362
UNITED STATES TAX COURT
SUDHIR P. SRIVASTAVA AND ELIZABETH S. PASCUAL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26605-95. Filed October 6, 1998.
Michael D. Cropper, for petitioners.
W. Mark Scott, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined deficiencies in, and
penalties on, the Federal income tax for 1991 and 19921 of Sudhir
P. Srivastava (petitioner) and Elizabeth S. Pascual (Pascual) as
follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1991 $1,188,920 $237,784
1992 33,037 6,607
1 The deficiency for 1992 is for petitioners' short taxable
year that began on Jan. 1, 1992, and ended July 7, 1992.
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