T.C. Memo. 1998-414
UNITED STATES TAX COURT
GREGORY C. WELTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5035-97. Filed November 17, 1998.
Gregory C. Welton, pro se.
Steven L. Walker, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: In a notice of deficiency issued to Gregory
C. Welton on December 13, 1996, respondent determined a $53,692
deficiency in, and a $9,506 section 6662(a) penalty relating to,
Mr. Welton's 1994 Federal income tax. All section references are
to the Internal Revenue Code in effect for the year in issue, and
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