T.C. Memo. 2001-177
UNITED STATES TAX COURT
THOMAS N. CARMENA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3412-99. Filed July 19, 2001.
Barbara Sue Geil, for petitioner.
Timothy S. Sinnott, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined that
petitioner was liable for the following additions to tax for the
year 1982: $523 under section 6653(a)(1),1 50 percent of the
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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