T.C. Memo. 2000-212
UNITED STATES TAX COURT
RICHARD D. NELSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14125-98. Filed July 11, 2000.
Stanley Hagendorf and Wayne Hagendorf, for petitioner.
William R. McCants, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioner’s Federal income tax and accuracy-related penalties
under section 66621 for the 1991, 1992, and 1993 taxable years as
follows:
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable years under
consideration. Rule references are to the Tax Court’s Rules of
Practice and Procedure.
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