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...)
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