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.Page: 1 2 3 4 5 6 7 Next
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