T.C. Memo. 2001-200
UNITED STATES TAX COURT
TONY L. ZIDAR AND KATHLEEN I. ZIDAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11484-99. Filed August 1, 2001.
Jonathan V. Goodman, for petitioners.
Michael J. Calabrese, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: Respondent determined a $53,435 deficiency
in petitioners’ 1992 Federal income tax and a $10,687 addition to
tax under section 6662(a).1
1 All section references are to the Internal Revenue Code as
in effect for the taxable year in issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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