T.C. Memo. 2002-70
UNITED STATES TAX COURT
ANTONIO ROSARIO AND JOYCE ROSARIO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1378-00. Filed March 26, 2002.
Robert J. Fedor, for petitioners.
Katherine Lee Kosar, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$90,454 in petitioners’ Federal income tax for 1993. The issues
for decision are whether $242,556 received by petitioner Antonio
Rosario from Jesse Holman Jones Hospital (the hospital) in 1993
is taxable income to him in 1993 and whether the period of
limitations expired for the 1993 taxable year.
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