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 of
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