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 Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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