Scott L. Lafavre and Shari L. Lafavre - Page 1

                                  T.C. Memo. 2000-297                                   

                                UNITED STATES TAX COURT                                 

                SCOTT L. LAFAVRE AND SHARI L. LAFAVRE, Petitioners v.                   
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 1132-99.                Filed September 25, 2000.             

               Jeffrey W. Starbird, for petitioners.                                    
               Eric W. Johnson, for respondent.                                         

                                  MEMORANDUM OPINION                                    

               LARO, Judge:  This case is before the Court fully                        
          stipulated.  See Rule 1221.  Respondent determined a deficiency               
          in petitioners' 1994 Federal income tax in the amount of $43,938              
          and a penalty of $8,788 pursuant to section 6662(a).  After                   

               1 Rule references are to the Tax Court Rules of Practice and             
          Procedure.  Unless otherwise indicated, section references are to             
          the Internal Revenue Code in effect for the year in issue.                    

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