T.C. Memo. 1997-218
UNITED STATES TAX COURT
PHILLIP MORENO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11149-96. Filed May 8, 1997.
Phillip Moreno, pro se.
Christine V. Olsen, for respondent.
MEMORANDUM OPINION
LARO, Judge: The case is before the Court fully stipulated
under Rule 122. Phillip Moreno petitioned the Court to
redetermine respondent's determination of a $24,160 deficiency in
his 1992 Federal income tax. We must decide whether petitioner's
1992 gross income includes the gain that he realized in 1992 from
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