T.C. Memo. 2002-229
UNITED STATES TAX COURT
TERRI L. STEFFEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1296-92. Filed September 13, 2002.
B. Gray Gibbs,* for petitioner.
Michael A. Pesavento, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined additions to
petitioner’s1 1986 Federal income tax as follows:
*Mr. Gibbs represented petitioner at trial and on brief. On
Aug. 19, 2002, he was granted leave to withdraw as counsel of
record.
1Petitioner and her husband, Paul A. Bilzerian, filed a
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