T.C. Memo. 2002-59
UNITED STATES TAX COURT
GENE C. SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18639-99L. Filed February 28, 2002.
Gene C. Smith, pro se.
Joanne B. Minsky, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioner petitioned the Court under section
6330(d).1 We decide herein whether his income tax as assessed by
respondent for 1985, 1986, 1987, and 1988 should be reduced to
1 Section references are to the Internal Revenue Code
applicable to the relevant years.
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