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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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