United States Tax Court January 22, 2004, 16864-02L (Nield and Linda Montgomery v. Commissioner)

122 T.C. No. 1

UNITED STATES TAX COURT

NIELD AND LINDA MONTGOMERY, Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 16864-02L. Filed January 22, 2004.

Ps filed a joint Federal income tax return for the

taxable year 2000 reporting total tax of $2,831,360

and tax due of $196,006. Ps failed to remit the latter

amount with their tax return.