T.C. Memo. 1995-574
UNITED STATES TAX COURT
BERNARD MICHAEL REED, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23518-93. Filed December 4, 1995.
Bernard Michael Reed, pro se.
Paul L. Dixon, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181 and 182.1 Respondent
determined a deficiency in petitioner's 1991 Federal income tax
in the amount of $1,504, and an accuracy-related penalty pursuant
to section 6662(b)(1) in the amount of $300.80.
The issues for decision are: (1) Whether petitioner's real
estate and water purifier activities were engaged in for profit
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1991, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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