T.C. Memo. 1998-250
UNITED STATES TAX COURT
CHARLES F. SUTTER AND CHERYL SUTTER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10357-96. Filed July 8, 1998.
Laura Lee Anderson, for petitioners.
Michael W. Lloyd, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. Section references are to the Internal Revenue Code in
effect for the years 1991 and 1992. Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners' 1991 and
1992 Federal income taxes in the amounts of $1,080 and $1,387,
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