Paul F. Belloff v. Commissioner of Internal Revenue

MAHONEY, Circuit Judge:

Petitioner-appellant Paul F. Belloff appeals from a decision of the United States Tax Court, Charles E. Clapp II, Judge, entered October 18, 1991 that determined a deficiency in income tax due from Belloff for 1986 in the amount of $17,137, a penalty pursuant to 26 U.S.C. § 6653(a)(1)(A) 1 in the amount of $856.85, and penalty interest pursuant to § 6653(a)(1)(B). These determinations ensued from an opinion of the Tax Court, Belloff v. Commissioner, 62 T.C.M. (CCH) 274, 1991 WL 138571 (1991), whose primary ruling was that the Tax Court lacked jurisdiction to consider…