T.C. Memo. 2002-261 UNITED STATES TAX COURT CARL L. HENN AND EUGENIA T. HENN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9895-00. Filed October 9, 2002. E. Martin Davidoff, for petitioners. Rodney J. Bartlett and Timothy S. Sinnott, for respondent. MEMORANDUM OPINION DINAN, Special Trial Judge: Respondent determined that petitioners are liable for additions to tax for taxable year 1982 under section 6653(a)(1) and (2) in the respective amounts of $256 and 50 percent of the interest due on a $5,124 deficiency. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and allPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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