T.C. Memo. 2006-261 UNITED STATES TAX COURT FRANK M. SETTIMO AND SALLYN M. SETTIMO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5153-05. Filed December 7, 2006. Joseph Falcone, for petitioners. Laurie B. Schmidt and John W. Stevens, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioners petitioned the Court to redetermine respondent’s determination of deficiencies of $18,243 and $19,917 in their 2001 and 2002 Federal income taxes, respectively, and section 6662 accuracy-related penalties of $3,648.60 and $3,983.40, respectively. Following the parties’ concessions, we are left to decide whether two S corporationsPage: 1 2 3 4 5 6 Next
Last modified: May 25, 2011