T.C. Memo. 2005-163
UNITED STATES TAX COURT
EUGENE A. SANDERS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25134-96. Filed July 5, 2005.
Douglas Alan Azar, for petitioner.
Nhi T. Luu-Sanders, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: In what is commonly referred
to as an affected item notice of deficiency, respondent
determined a section 6662(a)1 accuracy-related penalty of $8,411
(amounts are rounded) with respect to petitioner’s 1991 Federal
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for 1991, and Rule references are
to the Tax Court Rules of Practice and Procedure.
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