John Christopher Singleton - Page 1

                                 T.C. Memo. 1996-249                                  

                               UNITED STATES TAX COURT                                

                      JOHN CHRISTOPHER SINGLETON, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4164-94.               Filed May 30, 1996.                  

               John C. Singleton, pro se.                                             
               T. Keith Fogg and Veena Luthra, for respondent.                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               JACOBS, Judge: Respondent determined that petitioner in his            
          capacity as a fiduciary of the Estate of Marguerite B. Greer                
          (sometimes referred to as the Estate) was personally liable under           
          31 U.S.C. section 3713(b) (1994) for unpaid estate taxes owing by           
          the Estate in the amount of $32,443, plus interest. Respondent              

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