T.C. Memo. 2000-195
UNITED STATES TAX COURT
NORMAN H. FAWSON AND MARY JANE B. FAWSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7705-99. Filed June 28, 2000.
Bruce E. Babcock, for petitioners.
Richard W. Kennedy, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: Respondent issued a notice of
deficiency to petitioners for taxable year 1982. In the notice,
respondent determined that petitioners were liable for additions
to tax for negligence pursuant to section 6653(a)(1)1 of $509.75
and pursuant to section 6653(a)(2) for 50 percent of the interest
1 Unless otherwise indicated, 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
Procedure.
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