T.C. Memo. 2000-151
UNITED STATES TAX COURT
JOHN S. HALPERN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13245-96. Filed April 28, 2000.
Richard A. Levine, for petitioner.
Michael A. Menillo and Tyrone J. Montague, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to Rules 180, 181, and 183.
All Rule references are to the Tax Court Rules of Practice and
Procedure. The Court agrees with and adopts the opinion of the
Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: By notice of deficiency
respondent determined additions to tax under sections 6653(a)(1)
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