T.C. Memo. 2000-60 UNITED STATES TAX COURT ANTONIO & LUZVIMINDA PUNGOT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20036–97. Filed February 24, 2000. Richard J. Sapinski, for petitioners. Robert F. Saal and Guy G. Lavignera, for respondent. MEMORANDUM OPINION FAY, Judge: Respondent determined deficiencies of $10,756 and $10,974 in petitioners’ 1994 and 1995 Federal income taxes, respectively. After concessions, the issue for decision is whether section 469(c)(7)(D)(ii)1 is unconstitutional. 1All section references are to the Internal Revenue Code in effect for 1994 and 1995, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise noted.Page: 1 2 3 4 5 6 7 8 9 Next
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