Lindley Anthony Swanston - Page 1

                                 T.C. Memo. 1997-103                                  

                               UNITED STATES TAX COURT                                

                       LINDLEY ANTHONY SWANSTON, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8261-95.              Filed February 27, 1997.              

               Lindley Anthony Swanston, pro se.                                      
               Charles M. Ruchelman, for respondent.                                  

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.               
               Respondent determined a deficiency in Federal income tax of            
          $2,929.75 and the addition to tax under section 6651(a)(1) in the           
          amount of $732.43 for petitioner's 1988 tax year.                           

               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.            

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