T.C. Memo. 1998-57
UNITED STATES TAX COURT
RANDAL W. HOWARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20474-90. Filed February 11, 1998.
Randal W. Howard, pro se.
Rachael J. Zepeda, 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.
In separate notices of deficiency, respondent determined the
following deficiencies in petitioner's Federal income taxes and
additions to tax:
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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