Shirley Dean Powers, a.k.a. Shirley Powers Gilchrist - Page 6

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          318; Willis v. Commissioner, T.C. Memo. 2003-302; O’Brien v.                
          Commissioner, T.C. Memo. 2003-290; Schulman v. Commissioner, T.C.           
          Memo. 2002-129.  Petitioner’s OIC of $100 was not based on any              
          analysis.  Petitioner failed to provide information or explain              
          how she arrived at her conclusions.  Indeed, when the Court asked           
          petitioner to explain why she disagreed with respondent’s                   
          analysis of her OIC, she failed to provide an adequate                      
          explanation.  We are satisfied that respondent did not abuse his            
          discretion in making his determination.                                     
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To give effect to the foregoing,                                       

                                             An appropriate decision will             
                                        be entered for respondent.                    






















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