T.C. Memo. 1999-348
UNITED STATES TAX COURT
DALE C. AND JACQUELINE L. HOLT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 187-98. Filed October 20, 1999.
Stephen D. Willey, for petitioner.
James F. Prothro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PAJAK, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax in the amount of
$6,748, together with an accuracy-related penalty under section
6662(a) in the amount of $1,350, for the taxable year 1995. All
section references are to the Internal Revenue Code in effect for
the year in issue.
On brief, respondent conceded that petitioners are not
liable for the accuracy-related penalty. Therefore, the only
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