T.C. Memo. 2000-161 UNITED STATES TAX COURT ESTATE OF KENNETH F. SCHOENEMAN, DECEASED, JOANN METZ AND JAMES J. RILEY, EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15230-97. Filed May 18, 2000. Sudhir R. Patel, for petitioners. James Fee and Michael D. Baker, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: By notice dated April 15, 1997, respondent determined deficiencies of $38,110, $38,098, and $18,119, and section 6662(a) penalties of $7,622, $7,620, and $3,624, relating to Kenneth Schoeneman’s 1993, 1994, and 1995 Federal income taxes, respectively. All section references are to the Internal Revenue Code in effect for the years in issue. The executors ofPage: 1 2 3 4 5 6 7 Next
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