Friend v. Commissioner

MICHAEL R. FRIEND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Friend v. Commissioner

Docket No. 16799-83

United States Tax Court

T.C. Memo 1990-144; 1990 Tax Ct. Memo LEXIS 168; 59 T.C.M. (CCH) 156; T.C.M. (RIA) 90144;

March 19, 1990

Michael R. Friend, pro se.

Jack A. Joynt and Phillip Owens, for the respondent.

PATE

MEMORANDUM FINDINGS OF FACT AND OPINION

PATE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rule 180 et seq. 1

Respondent determined a deficiency in petitioner's 1980 Federal income tax of $ 522. The issues for our…