T.C. Memo. 2001-183
UNITED STATES TAX COURT
ANTHONY B. AND JILL SERFUSTINI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14383-99. Filed July 23, 2001.
Anthony B. Serfustini, pro se.
Timothy S. Sinnott, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: In separate notices of
deficiency, respondent determined that petitioners were liable
for the following additions to tax for the years 1982 and 1983:1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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