T.C. Memo. 2002-154
UNITED STATES TAX COURT
JOHN FAVIA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9585-00. Filed June 18, 2002.
Lawrence A. Chez and Edward B. Chez, for petitioner.
Patricia Pierce Davis, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: For 1994, respondent determined a deficiency
in petitioner’s Federal income tax and an accuracy-related
penalty as follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $105,336 $21,067
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