T.C. Memo. 1997-375 UNITED STATES TAX COURT STEVEN MICHAEL RYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10828-96. Filed August 18, 1997. Steven Michael Ryan, pro se. Michael J. Calabrese, for respondent. MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1990 Federal income tax and an addition to tax under section 1 Section references are to the Internal Revenue Code in effect for the year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 Next
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