T.C. Memo. 1996-120
UNITED STATES TAX COURT
HORACE E. McCANN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 678-95. Filed March 12, 1996.
Horace E. McCann, pro se.
Horace Crump, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
By notice of deficiency dated November 3, 1994, respondent
determined a deficiency in petitioner's 1991 Federal income tax
and an accuracy-related penalty pursuant to section 6662(a) in
1 Section references are to the Internal Revenue Code in
effect for the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
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