Michael J. Sullivan and Maureen Sullivan - Page 2

                            T.C. Summary Opinion 2004-83                              


                               UNITED STATES TAX COURT                                


              MICHAEL J. SULLIVAN AND MAUREEN SULLIVAN, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5178-03S.            Filed June 24, 2004.                   

               Michael J. and Maureen Sullivan, pro sese.                             
               Frank N. Panza, for respondent.                                        


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.  Unless otherwise           
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue.                               
               Respondent determined for taxable year 2000 a deficiency in            
          petitioners' Federal income tax of $39,519 and an accuracy-                 
          related penalty of $2,314.                                                  





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