Kingsley v. Commissioner

MICHAEL J. KINGSLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kingsley v. Commissioner

Docket No. 11439-87

United States Tax Court

T.C. Memo 1990-79; 1990 Tax Ct. Memo LEXIS 79; 58 T.C.M. (CCH) 1428; T.C.M. (RIA) 90079;

February 20, 1990

Elliot D. Lobel, for the petitioner.

Charles Maurer, for the respondent.

RUWE

MEMORANDUM FINDINGS OF FACT AND OPINION OPINICN

RUWE, Judge: On December 12, 1986, a jeopardy assessment was made against petitioner for taxable years 1980, 1981, 1982, 1983, and 1984 pursuant to section 6861(a). 1 In a notice of deficiency dated February 3, 1987, respondent…