Legal Opinion

Ryan v. Commissioner

United States Tax Court

Decided February 7, 1991No. Docket No. 28614-86Unpublished

1Opinion of the Court

ROBERT N. RYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Ryan v. Commissioner

Docket No. 28614-86

United States Tax Court

T.C. Memo 1991-49; 1991 Tax Ct. Memo LEXIS 68; 61 T.C.M. (CCH) 1801; T.C.M. (RIA) 91049;

February 7, 1991, Filed

John L. Burghardt, for the petitioner.

Thomas M. Rohall, for the respondent.

SHIELDS, Judge.

SHIELDS

MEMORANDUM OPINION

Respondent determined a deficiency of $ 17,550 in petitioner's Federal income tax for 1981. In his answer respondent asserted an undetermined amount of additional interest pursuant to section 6621(c) (formerly section 6621(d)). 1 The…

2Cases cited19 opinions

  1. Jacklin v. CommissionerUnited States Tax Court · 1982
  2. Espinoza v. CommissionerUnited States Tax Court · 1982
  3. Adler v. CommissionerUnited States Tax Court · 1985
  4. Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
  5. David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988

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