T.C. Memo. 1996-254
UNITED STATES TAX COURT
ORVILLE E. CHRISTENSEN AND HELEN V. CHRISTENSEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12706-94. Filed June 3, 1996.
Louis S. Weller, for petitioners.
Cynthia K. Hustad, for respondent.
MEMORANDUM OPINION
K�RNER, Judge: By timely notice of deficiency, respondent
determined deficiencies in petitioners' Federal income tax in the
amounts of $220,039 for 1988 and $240 for 1989. The case was
submitted to the Court on a set of fully stipulated facts and
exhibits under Rule 122. Except as hereinafter noted, all
statutory references are to the Internal Revenue Code in effect
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