Joseph J. James - Page 1

                                       T.C. Memo. 1995-562                                             

                                     UNITED STATES TAX COURT                                           

                                 JOSEPH J. JAMES, Petitioner v.                                        
                       COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket No. 25196-92.            Filed November 27, 1995.                             

                  Joseph J. James, pro se.                                                             
                  Michael D. Baker, for respondent.                                                    

                           MEMORANDUM FINDINGS OF FACT AND OPINION                                     

                  PARR, Judge:  Respondent determined a deficiency in                                  
            petitioner's Federal income tax for 1986 of $8,414 and an                                  
            addition to tax for substantial understatement of tax under                                
            section 66611 of $2,104.                                                                   

                  All section references are to the Internal Revenue Code in                           
            effect for the taxable year in issue, and all Rule references are                          
            to the Tax Court Rules of Practice and Procedure, unless                                   
            otherwise indicated.                                                                       

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