T.C. Memo. 2006-267
UNITED STATES TAX COURT
NATHANIEL H. AND CAROL A. GARFIELD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4017-05. Filed December 18, 2006.
Ronald J. Cohen and David S. Schwan, for petitioners.
Frank J. Jackson and Karen A. Rennie, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The issues for decision are whether income
received by petitioners should be treated as ordinary income or
long-term capital gain and whether petitioners are liable for the
section 66621 accuracy-related penalty.
1 Unless otherwise indicated, all section references are to
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