Theodore W. Keller - Page 1

                                         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                              

                  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                                    

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