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.
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