T.C. Memo. 2001-162
UNITED STATES TAX COURT
NICHOLAS P. RUGGIERO AND ANNETTE M. RUGGIERO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9561-00. Filed July 3, 2001.
Nicholas P. Ruggiero and Annette M. Ruggiero, pro sese.
Timothy S. Sinnott, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: Respondent determined additions
to petitioners' Federal income tax for 1983 under section
6653(a)(1)1 in the amount of $167.25 and under section 6653(a)(2)
in the amount of 50 percent of the interest due on the portion of
1All section references are to the Internal Revenue Code in
effect for the taxable year in issue.
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