T.C. Memo. 1996-222
UNITED STATES TAX COURT
BARRY I. FREDERICKS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16442-92. Filed May 9, 1996.
Barry I. Fredericks, pro se.
Talitha L. Poulin and Francis J. Strapp, Jr., for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency in
petitioner's and his ex-wife's 1977 Federal income tax in the
amount of $28,361, plus increased interest under section
6621(c).1 The sole issue for decision is whether a Form 872-A
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
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