T.C. Memo. 2001-308
UNITED STATES TAX COURT
LAUREL ANN CURTIS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 11125-95. Filed December 3, 2001.
On remand from the Court of Appeals for the Ninth
Circuit to elaborate the evidence relied on by the
Court in Curtis v. Commissioner, T.C. Memo. 1996-484,
revd. and remanded without published opinion 232 F.3d
893 (9th Cir. 2000), to conclude that respondent had
provided the minimal evidentiary foundation supporting
his determination of unreported income. See
Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir.
1979), revg. 67 T.C. 672 (1977).
Held: Findings made to support conclusion that
proper foundation exists.
* This opinion supplements Curtis v. Commissioner, T.C.
Memo. 1996-484, revd. and remanded without published opinion 232
F.3d 893 (9th Cir. 2000).
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