Donald John Vitale - Page 1

                                 T.C. Memo. 1999-272                                  

                               UNITED STATES TAX COURT                                

                          DONALD JOHN VITALE, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4655-97.             Filed August 12, 1999.                 

               Donald John Vitale, pro se.                                            
               Richard A. Stone, 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            
               Respondent determined a deficiency in petitioner's 1994                
          Federal income tax in the amount of $2,006.  The sole issue is              
          the fair market value in 1972 of a bronze statue attributed to              

               1  Unless otherwise indicated, section references are to the           
          Internal Revenue Code in effect for the year in issue, and Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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