T.C. Memo. 2002-122
UNITED STATES TAX COURT
JAMES R. AND MYRTICE L. PEACOCK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6111-00. Filed May 15, 2002.
Robert N. Reynolds and Ronald Cutler, for petitioners.
Felicia Branch and Benjamin De Luna, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine deficiencies in their 1995, 1996, and 1997 Federal
income taxes, an addition to their 1997 tax under section
6651(a)(1), and accuracy-related penalties under section 6662(a).
Respondent determined for the respective years deficiencies of
$132,801, $40,330, and $97,992 and accuracy-related penalties of
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