T.C. Memo. 2006-128
UNITED STATES TAX COURT
CHESTER H. AND MICHELLE R. ROSSMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20095-03. Filed June 20, 2006.
Ps failed to file Federal income tax returns for
the 1997, 1998, 1999, and 2000 taxable years. R
determined deficiencies and additions to tax under sec.
6651(f), I.R.C., or alternatively, under sec.
6651(a)(1), I.R.C.
Held: P-H is liable for additions to tax for the
years in issue under sec. 6651(f), I.R.C.
Edward G. Marshall, for petitioners.
Paul L. Dixon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent’s statutory notice of deficiency
dated August 21, 2003, determined deficiencies and additions to
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