Bud Raymond - Page 1

                                 T.C. Memo. 2001-96                                   

                               UNITED STATES TAX COURT                                

                             BUD RAYMOND, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18162-99.                   Filed April 17, 2001.           

               Bud Raymond, pro se.                                                   
               Andrew R. Moore, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined a deficiency of                 
          $140,981 in petitioner’s 1995 Federal income tax.  After                    
          concessions,1 the issues for decision are (1) the amount realized           

               1  With regard to items listed in the notice of deficiency,            
          respondent concedes that petitioner is entitled to a $3,000                 
          capital loss relating to the sale of baseball cards and $23,935             
          of deductions on Schedule A, Itemized Deductions.  As to                    

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