T.C. Memo. 2001-16
UNITED STATES TAX COURT
MICHAEL G. HARVEY AND PENNY B. HARVEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9527-99. Filed January 25, 2001.
Joel N. Crouch and Sarah Q. Qureshi, for petitioners.
Rodney J. Bartlett, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: Respondent determined that
petitioner was liable for the following additions to tax for
taxable year 1982: $452.25 under section 6653(a)(1), 50 percent
of the interest due on a $9,045 deficiency under section
6653(a)(2), and $2,261.25 under section 6661. Unless otherwise
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