Norman H. Fawson and Mary Jane B. Fawson - Page 1

                                 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              

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