T.C. Memo. 2001-106
UNITED STATES TAX COURT
JAMES TINNELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20318-97. Filed May 4, 2001.
W. Leslie Sully, Jr., for petitioner.
Paul L. Dixon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: Respondent determined the following
deficiencies, additions to tax, and penalties with respect to
petitioner’s Federal income taxes:1
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
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