T.C. Memo. 1999-158 UNITED STATES TAX COURT LUCIO AMBROSELLI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8355-97. Filed May 11, 1999. Lucio Ambroselli, pro se. Daniel J. Parent, for respondent. MEMORANDUM OPINION GERBER, Judge: Respondent determined a $122,460 income tax deficiency and a $91,845 fraud penalty under section 66631 for petitioner’s 1993 taxable year. We consider whether petitioner should be defaulted in connection with respondent’s motion to 1 Section references are to the Internal Revenue Code in effect for the period under consideration. Rule references are to this Court’s Rules of Practice and Procedure.Page: 1 2 3 4 5 6 Next
Last modified: May 25, 2011