T.C. Memo. 2000-262
UNITED STATES TAX COURT
MICHAEL E. AND LINDA S. MURRAY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1640-98. Filed August 17, 2000.
Robert H. Culton II, for petitioners.
Randall B. Pooler, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case was submitted to the Court without
trial under Rule 122. Petitioners petitioned the Court to
redetermine a $1,072,177 deficiency in their 1993 Federal income
tax, a $268,044 addition thereto under section 6651(a)(1), and a
$214,435 accuracy-related penalty under section 6662. Following
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