James Lindsey and Lynne Lindsey - Page 1

                                 T.C. Memo. 2002-278                                  

                               UNITED STATES TAX COURT                                

                   JAMES LINDSEY AND LYNNE LINDSEY, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6425-02.               Filed November 4, 2002.              

               James Lindsey and Lynne Lindsey, pro sese.                             
               Bradley Taylor, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  Petitioners, while residing in Big Bear Lake,            
          California, petitioned the Court to redetermine respondent’s                
          determination that they are liable for an accuracy-related                  
          penalty of $2,754.40 under section 6662(d).  The determination,             
          which relates to 1996, arises out of certain adjustments which              
          respondent made to the income of a partnership in which                     

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