T.C. Memo. 2002-18
UNITED STATES TAX COURT
MARK CHRISTOPHER AND NANCY LOUISE CORCORAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2947-01. Filed January 18, 2002.
Mark Christopher Corcoran, pro se.
Timothy F. Salel, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: Respondent determined a
deficiency of $4,155 in petitioners’ 1998 Federal income tax. In
the answer to the petition respondent asserted an accuracy-
related penalty of $831 pursuant to section 6662(a). At trial
respondent filed a written motion for a penalty under section
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