T.C. Memo. 2001-71
UNITED STATES TAX COURT
CLAYTON W. PLOTKIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13365-99. Filed March 23, 2001.
Wayne A. Smith, for petitioner.
Charles B. Burnett and J. Robert Cuatto, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a $12,188 deficiency
in petitioner’s 1994 Federal income tax as well as a $2,437.60
section 6662(a)1 accuracy-related penalty. The first issue for
decision is whether the amount which petitioner received as a
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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