Thomas E. King - Page 1

                                         T.C. Memo. 1996-52                                               

                                      UNITED STATES TAX COURT                                             

                                  THOMAS E. KING, Petitioner v.                                           
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 1161-94.              Filed February 13, 1996.                               

                  Steven C. Bublitz, for petitioner.                                                      
                  Robert J. Burbank, for respondent.                                                      

                                         MEMORANDUM OPINION                                               
                  GOLDBERG, Special Trial Judge: This case was heard pursuant                             
            to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent                              
            determined a deficiency in petitioner's Federal income tax for                                
            taxable year 1990 in the amount of $2,481.  After a concession by                             

            1     Unless otherwise indicated, all section references are to                               
            the Internal Revenue Code in effect for the year in issue.  All                               
            Rule references are to the Tax Court Rules of Practice and                                    

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