T.C. Memo. 1996-161
UNITED STATES TAX COURT
TED COWAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23292-94. Filed March 28, 1996.
Ted Cowan, pro se.
Julie L. Payne, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1 Respondent determined a deficiency in petitioner's 1989
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
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