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 for
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