T.C. Memo. 1996-403
UNITED STATES TAX COURT
BILL R. AND CAROLINA N. THOMAS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12096-94. Filed August 27, 1996.
Kenneth Alan Thomas, for petitioners.
Alvin A. Ohm, 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 petitioners' Federal income tax for
1991 in the amount of $1,335. After concessions, the issue for
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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