Anna Ruth French - Page 1
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T.C. Memo. 1996-38
UNITED STATES TAX COURT
ANNA RUTH FRENCH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3265-94. Filed February 1, 1996.
Jerold K. Nussbaum, for petitioner.
Helen F. Rogers, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax for taxable year 1986 in the
amount of $123,862. Respondent further determined that
petitioner is liable for an addition to tax in the amount of
$12,386 pursuant to section 66611 for a substantial
understatement of income tax. The issues for decision are:
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
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