T.C. Memo. 2000-353
UNITED STATES TAX COURT
EDWARD G. SMITH AND JAN M. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10833-99. Filed November 14, 2000.
Larry D. Vince, for petitioners.
Timothy F. Salel, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Chief Judge: Respondent determined a deficiency of
$46,283 in petitioners’ Federal income tax for 1995. Unless
otherwise indicated, section references are to sections of the
Internal Revenue Code, as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure. The deficiency is
attributable to an adjustment to the taxable income reported by
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