Legal Opinion

Theophilos v. Commissioner

United States Tax Court

Decided February 7, 1994No. Docket No. 8450-91UnpublishedCited by 1 opinion

1Opinion of the Court

ANTHONY THEOPHILOS AND PATRICIA A. THEOPHILOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Theophilos v. Commissioner

Docket No. 8450-91

United States Tax Court

T.C. Memo 1994-45; 1994 Tax Ct. Memo LEXIS 47; 67 T.C.M. (CCH) 2106;

February 7, 1994, Filed

Decision will be entered under Rule 155.

For petitioners: *Martin A. Schainbaum1 and Donald R. Share.

For respondent: Mary Wynne.

JACOBS

JACOBS

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge: Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:

Additions to Tax

Year

Deficiency

Sec.…

2Cases cited19 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. United States v. CartwrightSupreme Court of the United States · 1973
  3. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  4. Pallottini v. CommissionerUnited States Tax Court · 1988
  5. Marcello v. CommissionerUnited States Tax Court · 1964

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3Cited by1 opinion

  1. Stephen D. Pahl Louise A. Pahl v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998

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