T.C. Memo. 2007-173
UNITED STATES TAX COURT
TIMOTHY AND BARBARA KOSINSKI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9911-04. Filed July 2, 2007.
Neal Nusholtz and Richard M. Lustig, for petitioners.
Timothy S. Murphy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of
$1,205,548 and an addition to tax for fraud pursuant to section
6663 of $904,161 with respect to petitioners’ Federal income tax
for 1997. Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year in issue, and
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Last modified: November 10, 2007