Anna Ruth French - Page 1

          T.C. Memo. 1996-38                                                          

                               UNITED STATES TAX COURT                                

                           ANNA RUTH FRENCH, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3265-94.              Filed February 1, 1996.               

               Jerold K. Nussbaum, for petitioner.                                    
               Helen F. Rogers, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WRIGHT, Judge:  Respondent determined a deficiency in                  
          petitioner’s Federal income tax for taxable year 1986 in the                
          amount of $123,862.  Respondent further determined that                     
          petitioner is liable for an addition to tax in the amount of                
          $12,386 pursuant to section 66611 for a substantial                         
          understatement of income tax.  The issues for decision are:                 

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect during the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              

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