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.Page: 1 2 3 4 5 Next
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