T.C. Memo. 1997-63
UNITED STATES TAX COURT
CRAIG V. ADAMS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10587-95. Filed February 4, 1997.
Clinton A. Jackson, for petitioner.
Charles M. Ruchelman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: Respondent determined a deficiency of
$30,394 in petitioner's Federal income tax for 1991 and an
accuracy-related penalty of $6,078 pursuant to section 6662(a).
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
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