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
Procedure.
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