T.C. Memo. 2000-107
UNITED STATES TAX COURT
MATTI KOSONEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4259-98. Filed March 28, 2000.
Andrew I. Panken and Robert A. DeVellis, for petitioner.
Carmino J. Santaniello, Bradford A. Johnson, Gerald A.
Thorpe, and Frances Regan, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: Respondent determined that petitioner is
liable for deficiencies in income tax of $20,369 for 1994 and
$24,747 for 1995.
The issue for decision is whether, as petitioner contends,
petitioner elected under section 469(c)(7) to treat his seven
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