T.C. Memo. 1997-320
UNITED STATES TAX COURT
JAMES A. PICARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2768-95. Filed July 9, 1997.
Martin J. Tierney and D. Dewey Watson, for petitioner.
Kevin G. Croke, for respondent.
MEMORANDUM OPINION
GALE, Judge: Respondent determined a deficiency of $3,169
in petitioner's 1992 Federal income tax and an addition to tax
pursuant to section 6651(a)1 of $782.25. This case was submitted
1Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
(continued...)
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