T.C. Memo. 1999-351
UNITED STATES TAX COURT
ROCKWELL BANKER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22332-97. Filed October 25, 1999.
Rockwell Banker, pro se.
Karen N. Sommers, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioner's Federal income tax in the amount of
$5,500 and an accuracy-related penalty pursuant to section
6662(a) in the amount of $1,100 for the taxable year 1994.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and all
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