T.C. Memo. 1997-16
UNITED STATES TAX COURT
LESLIE S. HIRAHARA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23603-94. Filed January 8, 1997.
Leslie S. Hirahara, pro se.
Jonathan J. Ono, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioner's 1991 Federal income tax in the amount of $76,076,
and a penalty under section 6662(a)1 in the amount of $13,953.
1 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, unless otherwise
indicated.
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