T.C. Memo. 2002-197
UNITED STATES TAX COURT
PERRY H. KAY, SR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10828-00. Filed August 8, 2002.
Emil R. Sargent, for petitioner.
Portia N. Rose, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioner’s Federal income tax for the taxable
year 1998 in the amount of $4,181.50. Unless otherwise
indicated, section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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