T.C. Memo. 2001-17
UNITED STATES TAX COURT
JOHN Y. & MARION ROBNETT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8561-99. Filed January 26, 2001.
Hugh O. Mussina, 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: $1,070 under section 6653(a)(1), 50 percent
of the interest due on a $21,404 deficiency under section
6653(a)(2), and $5,351 under section 6661. Unless otherwise
indicated, section references are to the Internal Revenue Code in
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