T.C. Memo. 1996-481
UNITED STATES TAX COURT
ARVID E. JACKSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3682-95. Filed October 24, 1996.
Theodore K. Jackson III, for petitioner.
Charles Pillitteri, for respondent.
MEMORANDUM OPINION
SCOTT, Judge: Respondent determined deficiencies in
petitioner's Federal income taxes for the calendar years 1991 and
1992 in the amounts of $7,276.01 and $7,070.43, respectively.
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
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