T.C. Memo. 1999-371
UNITED STATES TAX COURT
MARK AND HELEN THOMSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23704-97. Filed November 8, 1999.
Conrad D. Carnes, for petitioners.
Jean Bass and Nguyen-Hong K. Hoang, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
ciencies in, and accuracy-related penalties under section
6662(a)1 on, petitioners' Federal income tax:
1All section references are to the Internal Revenue Code
(Code) in effect for the years at issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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