Reinhardt v. Commissioner

VIRGIL E. AND LORRAINE REINHARDT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Reinhardt v. Commissioner

Docket No. 12321-92

United States Tax Court

T.C. Memo 1993-397; 1993 Tax Ct. Memo LEXIS 408; 66 T.C.M. (CCH) 566;

August 30, 1993, Filed

Decision will be entered under Rule 155.

For petitioners: Raymond N. McCabe and Edward M. Griffith, Jr.

For respondent: Matthew I. Root.

COLVIN

COLVIN

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge: The primary issue in this case is whether additions to tax for either fraud or negligence apply to petitioners, who were distributors for the…