T.C. Memo. 2001-136
UNITED STATES TAX COURT
LARRY M. LEVY AND DIANE LEVY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11657-99. Filed June 8, 2001.
Larry M. Levy and Diane Levy, pro sese.
Kenneth C. Peterson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated March 25, 1999, respondent
determined deficiencies in and penalties on petitioners’ Federal
income taxes as follows:
Penalty
Year Deficiency Sec. 6662(a)
1991 $17,334 $3,467
1992 27,024 5,405
1994 48,671 9,734
Unless otherwise indicated, all section references are to the
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