T.C. Memo. 1996-193
UNITED STATES TAX COURT
EUGENE K. FRISCONE AND NICOLE FRISCONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7412-94. Filed April 22, 1996.
Kenneth J. Freeman, for petitioners.
Jeffry J. Erney, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined deficiencies in
petitioners' 1990 and 1991 income taxes, pursuant to sections
61(a)(3) and 1001(a),1 in the amounts of $10,307 and $1,817,
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
Rule references are to the Tax Court Rules of Practice and
Procedure.
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