T.C. Memo. 1998-314
UNITED STATES TAX COURT
JEFFREY C. AND KELLY O. STONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3812-97. Filed August 31, 1998.
Jeffrey C. and Kelly O. Stone, pro se.
Joan S. Dennett, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
petitioners' motion for summary judgment. For reasons stated
below, we deny petitioners' motion.
Respondent determined a deficiency in petitioners' Federal
income tax for 1994 of $10,959 and an accuracy-related penalty
for negligence under section 6662(a) in the amount of $2,192.
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