T.C. Memo. 2004-153
UNITED STATES TAX COURT
ROBERT B. KEMP, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5794-98, 143-00. Filed June 28, 2004.
John P. Konvalinka, for petitioner.
Monica D. Armstrong, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The issue for decision is whether petitioner
is liable for fraud penalties relating to 1991, 1992, and 1993.
FINDINGS OF FACT
In 1974, petitioner began operating Southeast Trust
Investment Management (Southeast Trust), a sole proprietorship
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