T.C. Memo. 1996-132
UNITED STATES TAX COURT
MARTIN FELDMAN AND LYNNE Z. GOLD-BIKIN, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27086-93. Filed March 18, 1996.
Barry H. Frank, for petitioners.
Joellyn R. Cattell, for respondent.
MEMORANDUM OPINION
HAMBLEN, Chief Judge: Respondent determined a deficiency in
petitioners' Federal income tax for the taxable year 1988 in the
amount of $31,700 and an addition to tax under section 6653(a)(1)
in the amount of $1,585. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the
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