T.C. Memo. 1996-42
UNITED STATES TAX COURT
JERRY SILVER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2057-94. Filed February 6, 1996.
Jerry Silver, pro se.
Alan R. Peregoy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax for taxable year 1989 in the
amount of $8,834. Respondent further determined that petitioner
is liable for additions to tax pursuant to sections 6651(a)1 and
1Unless otherwise indicated, all section references are to
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