T.C. Memo. 1998-212 UNITED STATES TAX COURT JOHN D. SMITH AND HAZEL B. SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26101-96. Filed June 16, 1998. Daniel J. Winfree, for petitioners. Timothy F. Salel, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year 1994. Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a deficiency in petitioners' 1994 Federal income tax in the amount of $2,783. The issues forPage: 1 2 3 4 5 6 7 8 Next
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