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 toPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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