T.C. Memo. 2001-186
UNITED STATES TAX COURT
PAUL E. AND JANE ANNE GLADDEN EMERSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10221-99. Filed July 23, 2001.
Paul E. and Jane Anne Gladden Emerson, pro se.
Joanne B. Minsky, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax in the amount of
$6,046 and a section 6662(a) penalty in the amount of $1,209.20
for the taxable year 1995. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
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