T.C. Memo. 1996-300
UNITED STATES TAX COURT
THEODORE W. KELLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1284-95. Filed June 27, 1996.
Theodore W. Keller, pro se.
Jeremy L. McPherson, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
Respondent determined a deficiency of $2,996 in petitioner's
Federal income tax and an accuracy-related penalty under section
1
When the petition was filed, petitioner elected to have this
case considered pursuant to sec. 7463(a) as a small tax case.
Prior to trial, petitioner requested that the case be considered
pursuant to sec. 7443A(b)(3). The Court granted petitioner's
request. Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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