Adel Abdalla - Page 1

                                 T.C. Memo. 1996-111                                  

                               UNITED STATES TAX COURT                                

                             ADEL ABDALLA, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21678-94.             Filed March 11, 1996.                 

               Linda S. Bednarz and Kenneth J. Rubin, for respondent.                 

                                 MEMORANDUM OPINION                                   
               VASQUEZ, Judge:  This case is before the Court on                      
          respondent's motion for entry of default judgment pursuant to               
          Rule 123(a).1  By separate notices of deficiency, respondent                
          determined additions to petitioner's Federal income tax for fraud           
          under section 6653(b), as follows:2                                         

          1  All Rule references are to this Court's Rules of Practice and            
          Procedure, and all section references are to the Internal Revenue           
          Code in effect for the years in issue.                                      
          2  Prior to the issuance of the notices of deficiency, but                  

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