T.C. Memo. 1998-36 UNITED STATES TAX COURT NEIL M. BAIZER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21046-94. Filed January 27, 1998. Frederick A. Romero, for petitioner. Clifton B. Cates III, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WRIGHT, Judge: Respondent determined deficiencies in petitioner's excise taxes imposed on prohibited transactions by section 49751 and additions to tax2 as follows: 1 All section references are to the Internal Revenue Code in effect for the years at issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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