Stephen Kowalchuk - Page 1

                                  T.C. Memo. 2000-153                                   

                                UNITED STATES TAX COURT                                 

                           STEPHEN KOWALCHUK, Petitioner v.                             
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       
               Docket No. 1434-95.                       Filed May 5, 2000.             

               Stephen Kowalchuk, pro se.                                               
               Louise R. Forbes, for respondent.                                        

                                  MEMORANDUM OPINION                                    
               POWELL, Special Trial Judge: Respondent determined that                  
          petitioner is liable for additions to tax under sections                      
          6653(a)(1) and 6659 in the respective amounts of $199 and $844                
          for the taxable year 1982.1  In addition, respondent also                     
          determined that petitioner is liable for the addition to tax                  
          under section 6653(a)(2) in the amount of 50 percent of the                   

          1    Unless otherwise indicated, 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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