T.C. Memo. 2000-367
UNITED STATES TAX COURT
PAMELA OSOWSKI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10801-89. Filed December 4, 2000.
Burton W. Kanter, for petitioner.
Paul L. Darcy, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case was submitted to the Court fully
stipulated under Rule 122. Respondent determined a $5,416
deficiency in petitioner’s 1981 Federal income tax and additions
thereto of $270.80 and $1,624.80 under sections 6653(a)(1) and
6659, respectively. Respondent also determined as to the entire
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