T.C. Memo. 1996-314
UNITED STATES TAX COURT
PRISCILLA B. BADGER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15104-94. Filed July 11, 1996.
Priscilla B. Badger, pro se.
John T. Lortie, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: By two separate statutory notices of
deficiency each dated May 18, 1994, respondent determined
deficiencies in the amounts of $19,124 and $18,956 in
petitioner's 1990 and 1991 Federal income tax, respectively.
Respondent further determined additions to tax for failures to
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