Barry and Penny Knelman - Page 1

                                  T.C. Memo. 2000-268                                   

                                UNITED STATES TAX COURT                                 

                       BARRY AND PENNY KNELMAN, Petitioners v.                          
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 8397-99.                   Filed August 24, 2000.             

               Barry and Penny Knelman, pro sese.                                       
               Erica Y. Wu, for respondent.                                             

                       MEMORANDUM FINDINGS OF FACT AND OPINION                          
               VASQUEZ, Judge:  Respondent determined a deficiency of                   
          $11,790 and an accuracy-related penalty of $2,358 on petitioners’             
          1994 Federal income tax.  After concessions,1 the issues for                  

               1  In the notice of deficiency, respondent determined that               
          petitioners had underreported their income by $17,753.  After                 
          respondent conceded $3,198, petitioners stipulated that they had              
          received but failed to report $14,555 of operating income from                

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