T.C. Memo. 1999-69
UNITED STATES TAX COURT
DANIEL FRANCIS KELLY, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 750-97. Filed March 8, 1999.
Timothy F. Kelly, for petitioner.
Ann M. Welhaf, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
Respondent determined deficiencies of $3,850 and $1,063 in
petitioner's Federal income taxes for 1991 and 1992,
respectively.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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