Dale Allan Rinehart - Page 1

                                 T.C. Memo. 1998-205                                  

                               UNITED STATES TAX COURT                                

                         DALE ALLAN RINEHART, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 26402-96.            Filed June 11, 1998.                   

               Dale Allan Rinehart, pro se.                                           
               Brigham J.L. Sanders, for respondent.                                  

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined deficiencies in                 
          petitioner's 1992 and 1993 Federal income taxes in the amounts of           
          $43,959 and $44,656, respectively.                                          
               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure. After concessions,1              

               1  Petitioner concedes that he is not entitled to deduct               
          alimony in the amount of $9,288 for both 1992 and 1993 and                  

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