T.C. Memo. 1998-23
UNITED STATES TAX COURT
PAUL M. AND JUNE S. SENGPIEHL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18672-96. Filed January 20, 1998.
Paul M. Sengpiehl, for petitioners.
Naseem J. Khan and John Comeau, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1
Respondent determined a deficiency in petitioners' Federal
income tax for 1991 in the amount of $4,828.
1 All section references are to the Internal Revenue Code in
effect for the taxable year in issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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