T.C. Memo. 2004-40
UNITED STATES TAX COURT
ANTHONY J. AND DENISE D. SADBERRY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10499-02. Filed February 18, 2004.
Anthony J. and Denise D. Sadberry, pro se.
R. Scott Shieldes, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined a
deficiency of $22,255 in petitioners’ Federal income tax and a
penalty of $4,433 under section 6662(a) for the year 1999.1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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