Richard Clarke Randall - Page 1

                                  T.C. Memo. 2007-1                                   

                               UNITED STATES TAX COURT                                

                        RICHARD CLARKE RANDALL, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24208-05.          Filed January 3, 2007.                   

               Richard Clarke Randall, pro se.                                        
               Steven I. Josephy, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioner petitioned the Court to redetermine           
          a $14,643 deficiency in his 2003 Federal income tax and a $2,929            
          accuracy-related penalty under section 6662(a).1  Following a               
          trial that was held on September 11, 2006, we must decide whether           

               1 Section references are to the applicable versions of the             
          Internal Revenue Code.                                                      

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