William T. and Kathryn A. Kees - Page 1

                                 T.C. Memo. 1999-41                                   

                               UNITED STATES TAX COURT                                

                   WILLIAM T. AND KATHRYN A. KEES, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8467-95.              Filed February 8, 1999.               

               William T. Kees, pro se.                                               
               William Henck, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               GALE, Judge:  Respondent determined a deficiency in the                
          amount of $39,612 in petitioners’ 1992 Federal income tax, and an           
          accuracy-related penalty under section 6662(a)1 in the amount of            
          $7,922.  This case was submitted to the Court fully stipulated              

               1 Unless otherwise noted, all section references are to the            
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  

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