Robert W. and Vivian Toan - Page 1
















                                 T.C. Memo. 2000-384                                  


                               UNITED STATES TAX COURT                                


                    ROBERT W. AND VIVIAN TOAN, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17168-95.                Filed December 19, 2000.           



               Robert W. Toan and Vivian Toan, pro sese.                              
               Paul L. Darcy, for respondent.                                         


                                 MEMORANDUM OPINION                                   

               LARO, Judge:  This case was submitted to the Court fully               
          stipulated under Rule 122.  Respondent determined that                      
          petitioners were liable for $21, $3,099, and $578 additions to              
          their Federal income tax for 1979, 1980, and 1981, respectively,            
          under section 6659.  The additions to tax stem from respondent’s            





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