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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.
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Last modified: November 10, 2007