T.C. Memo. 2000-188
UNITED STATES TAX COURT
EDWARD D. LANG AND SHARON A. LANG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7280-97. Filed June 27, 2000.
Kevin Phillip Kennedy, for petitioners.
T. Richard Sealy III, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ Federal income taxes in the amounts of $104,221 for
1989, $136,986 for 1990, $161,458 for 1991, $93,890 for 1992, and
$76,200 for 1993. Respondent also determined that petitioners
are liable for the fraud penalty under section 6663 for each
year, but respondent now concedes they are not. Respondent
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