T.C. Memo. 2005-112
UNITED STATES TAX COURT
DENNIS E. RUNKLE AND DEBRA A. RUNKLE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17192-02. Filed May 18, 2005.
Dennis E. and Debra A. Runkle, pro sese.
Timothy A. Lohrstorfer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax for 1991 through and including
1995 (years at issue) and determined that petitioners were liable
for the addition to tax under section 6651(f)1 for fraudulent
1All section references are to the Internal Revenue Code in
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