T.C. Memo. 1997-536
UNITED STATES TAX COURT
HAROLD LEVINSON ASSOCIATES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9575-95. Filed December 3, 1997.
Richard M. Gabor, for petitioner.
Gary W. Bornholdt, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined deficiencies in
petitioner's Federal income taxes for the taxable years ending
January 31, 1990, and January 31, 1991, in the amounts of
$179,860 and $1,349, respectively. The remaining issue for
consideration is whether an amount paid to settle a lawsuit is a
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