T.C. Memo. 1998-102
UNITED STATES TAX COURT
ALTON C. BINGHAM, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2300-96. Filed March 12, 1998.
Alton C. Bingham, pro se.
Fred E. Green, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioner had an
income tax deficiency of $397,590 for 1984 and additions to tax
of $198,795 under section 6653(b)(1) and $99,398 under section
6661(a). Respondent also determined that petitioner was liable
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