T.C. Memo. 2004-42
UNITED STATES TAX COURT
MILTON L. HILDEBRAN AND JUDY W. HILDEBRAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13978-01. Filed February 19, 2004.
G. Paul Martin, for petitioner.
Veena Luthra, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined deficiencies of
$7,168 and $7,621 in petitioners’ Federal income tax for taxable
years 1998 and 1999, respectively.
The issue remaining for decision is whether certain wages
that petitioner Milton L. Hildebran (Mr. Hildebran) received
during each of the years at issue are excludable from petition-
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