T.C. Memo. 1998-33
UNITED STATES TAX COURT
BENJAMIN H. SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14945-96. Filed January 27, 1998.
Benjamin H. Smith, pro se.
Ron J. Mizrachi, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All
section references are to the Internal Revenue Code in effect for
the years in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure.
Respondent determined deficiencies in and accuracy-related
penalties on petitioner's Federal income taxes as follows:
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