T.C. Memo. 2001-59
UNITED STATES TAX COURT
LARRY M. PETTY AND JEAN L. PETTY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4038-99. Filed March 9, 2001.
Larry M. Petty and Jean L. Petty, pro sese.
Stephen P. Baker, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined deficiencies in,
additions under section 6651(a)(1)1 to, and accuracy-related
penalties under section 6662(a) on, petitioners’ Federal income
1All section references are to the Internal Revenue Code
(Code) in effect for the years at issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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