Bernard Michael Reed - Page 1

                                 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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