T.C. Memo. 2002-306
UNITED STATES TAX COURT
GEORGE J. MANTAKOUNIS AND SOPHIA MANTAKOUNIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5888-01. Filed December 17, 2002.
Ronald D. Ashby, for petitioners.
Jack T. Anagnostis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $34,106
in petitioners’ Federal income tax for 1991. Respondent also
determined an addition to tax of $10,024 under section 6651(a)(1)
and a penalty of $6,821 under section 6662(a). The issues for
decision are: (1) Whether petitioners failed to report $105,000
in income, (2) whether petitioners are liable for an addition to
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