T.C. Memo. 2004-63 UNITED STATES TAX COURT STEPHEN M. AND REBECCA A. KERNS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12728-02. Filed March 11, 2004. Charles Wist and Joan Kehlhof, for petitioners. John D. Faucher, for respondent. MEMORANDUM OPINION COLVIN, Judge: Respondent determined that petitioners are liable for deficiencies in Federal income tax of $3,357 for 1998 and $3,637 for 1999, and accuracy-related penalties under section 6662(a) of $671 for 1998 and $727 for 1999. After concessions, the sole issue for decision is whether a $7,800 payment by petitioner Stephen M. Kerns’s wholly ownedPage: 1 2 3 4 5 6 Next
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