T.C. Memo. 2000-215
UNITED STATES TAX COURT
REED-MERRILL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10494-98. Filed July 17, 2000.
Kandace C. Gerdes, for petitioner.
Joel A. Lopata, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated March 9, 1998, respondent
determined deficiencies of $23,938 and $92,548, and penalties,
pursuant to section 6662(a), of $4,787.60 and $18,509.60,
relating to petitioner’s 1993 and 1994 Federal income taxes,
respectively. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
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