Michael L. Goers - Page 1

                                 T.C. Memo. 1999-354                                   

                               UNITED STATES TAX COURT                                 

                           MICHAEL L. GOERS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 14152-97.                 Filed October 25, 1999.            

               Michael L. Goers, pro se.                                               
               Elizabeth Owen, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         
               GERBER, Judge:  Respondent determined an $11,458 deficiency             
          in petitioner’s 1994 income tax, a $2,864.50 addition for late               
          filing, and a $590.36 addition for failure to pay estimated tax.             
          The question presented in this case concerns whether the amounts             
          petitioner received as bank interest and compensation from third             
          parties constitute taxable income to him.                                    

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