T.C. Memo. 1997-344
UNITED STATES TAX COURT
DERK O. AND JULIA K. PEHRSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 343-96. Filed July 28, 1997.
Derk O. Pehrson, pro se.
Richard W. Kennedy, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
Although respondent determined a deficiency and addition to tax
totaling $10,193, the amount of deficiency placed in dispute by
petitioners (within the meaning of sec. 7463) does not exceed
$10,000.
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