T.C. Memo. 2000-156
UNITED STATES TAX COURT
PHILLIP M. WENGER, C.P.A., A SOLE PROPRIETOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5580-99. Filed May 12, 2000.
Phillip M. Wenger, pro se.
Roger P. Law, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioner's Federal excise tax under section
4971(a) for the taxable year 1994 in the amount of $1,828, as
well as an addition to tax under section 6651(a)(1) for failure
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