T.C. Memo. 2004-21
UNITED STATES TAX COURT
GARY AND JANET LUIZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6344-02. Filed January 29, 2004.
Anthony V. Diosdi, for petitioners.
Patricia Montero and Margaret S. Rigg, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax of $47,116 for 1996 and $23,475
for 1997.1
1 Respondent also determined that petitioners are liable
for the addition to tax for late filing under sec. 6651(a)(1) for
1996. Respondent now concedes that issue.
Unless otherwise specified, section references are to the
Internal Revenue Code as amended. Rule references are to the Tax
Court Rules of Practice and Procedure. References to petitioner
are to Gary Luiz.
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