T.C. Memo. 1998-214
UNITED STATES TAX COURT
JOANN THOMPSON, F.K.A. JOANN BATES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4702-97. Filed June 17, 1998.
Charles N. Woodward, for petitioner.
Elizabeth Downs, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
Respondent determined a deficiency in petitioner's 1994
Federal income tax and an addition to tax under section 6651(a)
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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