T.C. Memo. 2001-187
UNITED STATES TAX COURT
PAUL A. BILZERIAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10201-95. Filed July 24, 2001.
Paul A. Bilzerian, pro se.
Michael A. Pesavento, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined additions to
petitioner’s1 1986 Federal income tax as follows:
1Petitioner and his wife, Terri L. Steffen, filed a joint
return for 1986. Separate notices of deficiency were sent to
petitioner and Ms. Steffen and separate petitions were filed.
This Opinion addresses the liability of petitioner.
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