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)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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