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 corporations
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