T.C. Memo. 1997-252
UNITED STATES TAX COURT
SHIZUO GEORGE KURATA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5515-95. Filed June 4, 1997.
1. Held: Gain recognized because P failed to
prove sec. 1033, I.R.C., involuntary conversion of
property.
2. Held, further, deductions denied for
miscellaneous employee business expenses and for moving
expenses because P failed to substantiate such
expenditures.
3. Held, further, sec. 6651(a)(1), I.R.C.,
addition to tax for failure to file timely return
sustained.
4. Held, further, sec. 6662(a), I.R.C., accuracy
related penalty imposed for negligence or disregard of
rules or regulations.
Shizuo George Kurata, pro se.
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