T.C. Memo. 2003-269
UNITED STATES TAX COURT
WILLIAM B. MCDERMOTT AND DONNA MCDERMOTT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18050-99. Filed September 16, 2003.
William B. McDermott and Donna McDermott, pro sese.
Stephen S. Ash, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine a $215,493 deficiency in their 1995 Federal income
tax and a $43,099 accuracy-related penalty under section 6662(a).
Following respondent’s concession as to 17 of the 23 bank
deposits determined by him in the notice of deficiency to be
income, and our granting of petitioners’ motion to dismiss much
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