T.C. Memo. 1998-389
UNITED STATES TAX COURT
STEPHEN S. WANG, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15228-96. Filed November 2, 1998.
Mark D. Pastor and Robert T. Leonard, for petitioner.
Ronald M. Rosen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax for 1987 of $57,091, additions to
tax for fraud under section 6653(b)(1)(A)1 and (B) of $42,818 and
50 percent of the interest due on $57,091, respectively, and an
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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