T.C. Memo. 2002-53
UNITED STATES TAX COURT
JEFFREY S. AND SUSAN L. DUFFIELD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3716-00L. Filed February 25, 2002.
Joyce Griggs, for petitioners.
Ross M. Greenberg and Joanne B. Minsky, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: The issues in this case are whether
respondent has met the requirements of section 63301 and whether
petitioners are liable for the section 6673(a)(1) penalty.
Background
Jeffrey and Susan Duffield resided in Bear, Delaware, when
they filed their petition. The assessments relate to liabilities
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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