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 proprietorshipPage: 1 2 3 4 5 6 7 Next
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