T.C. Memo. 1996-98
UNITED STATES TAX COURT
RAYMOND ALBERT MOOREFIELD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17379-94. Filed March 5, 1996.
Raymond Albert Moorefield, pro se.
Maria A. Murphy and Michael Salama, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of
$310,670 in petitioner’s Federal income tax for 1988 and
additions to tax of $77,667 under section 6651(a)(1) and $15,749
under section 6653(a)(1). The issues for decision are whether
funds received by petitioner in 1988 constituted taxable income
and whether petitioner is liable for the additions to tax
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