T.C. Memo. 2005-49
UNITED STATES TAX COURT
MICHAEL P. AND PAMELA J. HOPKINS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7551-03. Filed March 17, 2005.
Daniel J. Cooper, for petitioners.
Karen Nicholson Sommers, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$51,643 in, and an accuracy-related penalty of $10,328.60 under
section 6662(a)1 on, petitioners’ Federal income tax (tax) for
1All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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