T.C. Memo. 2003-295
UNITED STATES TAX COURT
HORACE D’ANGELO, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8049-01. Filed October 23, 2003.
Neal Nusholtz, for petitioner.
Gregory C. Okwuosah, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioner petitioned the Court to redetermine
deficiencies of $35,742 and $26,756 in his 1995 and 1996 Federal
income taxes, respectively. Following concessions,1 we decide:
1 In addition to the explicit concessions, we consider
petitioner to have conceded respondent’s determination that he is
entitled to deduct certain prepaid expenses in 1996, not in 1995.
(continued...)
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