T.C. Memo. 1997-126
UNITED STATES TAX COURT
REINA MARTINEZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27007-95. Filed March 11, 1997.
Jack F. Bonanno, for petitioner.
Allan D. Hill, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: By notice dated October 5, 1995, respondent
determined a deficiency in petitioner's 1991 Federal income tax
of $159,551. After concessions, the issue for decision is
whether petitioner, pursuant to section 104(a)(2), is entitled to
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