T.C. Memo. 2002-11
UNITED STATES TAX COURT
KEVIN P. OSBORNE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5964-00. Filed January 10, 2002.
Kevin P. Osborne, pro se.
Peter C. Rock, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: Respondent determined
deficiencies in petitioner’s Federal income taxes of $10,267 and
$11,057, and penalties under section 6662(a) of $498.40 and
$259.40, for the taxable years 1996 and 1997. Unless otherwise
indicated, section references are to the Internal Revenue Code in
effect for the years in issue.
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