T.C. Memo. 2002-199
UNITED STATES TAX COURT
ROBERT M. AND NANCY I. STEWART, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 365-01. Filed August 8, 2002.
Martin Brant Fenster, for petitioners.
Matthew A. Mendizabal, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined deficiencies of $35,106
and $36,999 in petitioners’ Federal income taxes, and accuracy-
related penalties under section 6662(a)1 of $6,753 and $7,400,
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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