Universal Ins. Servs. v. Commissioner

UNIVERSAL INSURANCE SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Universal Ins. Servs. v. Commissioner

Docket No. 18684-90

United States Tax Court

T.C. Memo 1994-192; 1994 Tax Ct. Memo LEXIS 185; 67 T.C.M. (CCH) 2828;

April 28, 1994, Filed

Decision will be entered under Rule 155.

For petitioner: Martha Combellick Patrick.

For respondent: Anne Durning.

SHIELDS

SHIELDS

MEMORANDUM FINDINGS OF FACT AND OPINION

SHIELDS, Judge: Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:

Additions to tax

Sec.

Sec.

Sec.

Sec.

Year

Deficiency

6651

6653(a)(…