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 owned
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