Robin Adams - Page 1

                                 T.C. Memo. 1997-111                                  

                               UNITED STATES TAX COURT                                

                             ROBIN ADAMS, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17817-94.                    Filed March 4, 1997.           

               Robin Adams, pro se.                                                   
               Ann M. Murphy, 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 deficiencies in petitioner's 1990 and 1991 Federal               
          income taxes in the respective amounts of $3,529 and $3,694.                

          1    Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.  All            
          Rule references are to the Tax Court Rules of Practice and                  

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