T.C. Memo. 1996-71
UNITED STATES TAX COURT
JOHN EDWARD AND LINDA HALL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6300-94. February 21, 1996.
John Edward Hall, pro se.
Dennis R. Onnen, for respondent.
MEMORANDUM OPINION
K�RNER, Judge: Respondent determined a deficiency in
petitioners' 1990 Federal income tax in the amount of $22,217 and
a penalty under section 6662(a) in the amount of $5,281 for 1990.
All statutory references are to the Internal Revenue Code
in effect for the year in issue, and all Rule references are to
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