T.C. Memo. 2001-79
UNITED STATES TAX COURT
THOMAS J. ROSSER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1201-98. Filed March 30, 2001.
Carla I. Struble, for petitioner.
Gary R. Shuler, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioner’s income tax of $13,858 for 1993 and $24,697.91 for
1994, additions to tax for failure to timely file under section
6651(a) of $1,386 for 1993 and $6,175 for 1994, and an accuracy-
related penalty of $2,772 for 1993 and $4,939 for 1994 for a
substantial understatement of tax under section 6662(a).
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