- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background Respondent determined against petitioner tax deficiencies for 1988 and 1989 in the respective amounts of $59,032 and $72,150. The tax deficiencies related to petitioner’s income and expenses from her solo law practice. In 1996, as a resident of Minnesota, petitioner timely filed a petition in this Court disputing the above tax deficiencies that respondent had determined in petitioner’s Federal income taxes for 1988 and 1989. Westby v. Commissioner, T.C. Memo. 2004-179. On December 7, 2004, after a trial and opinion, a decision was entered in the above Tax Court case reflecting major downward adjustments in the tax deficiencies determined against petitioner by respondent; namely, the Court redetermined tax deficiencies in petitioner’s Federal income taxes for 1988 and 1989 of $4,250 and $2,635, respectively. On April 8, 2005, respondent assessed the above-redetermined and adjusted Federal income tax deficiencies against petitioner.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007