Courtney v. Commissioner

DANIEL B. COURTNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Courtney v. Commissioner

Docket No. 15476-92

United States Tax Court

T.C. Memo 1994-502; 1994 Tax Ct. Memo LEXIS 510; 68 T.C.M. (CCH) 908;

October 11, 1994, Filed

Decision will be entered in accordance with the stipulation of settled issues.

For petitioner: Mel Lamelas.

For respondent: Wayne A. S. Hamilton.

TANNENWALD

TANNENWALD

MEMORANDUM OPINION

TANNENWALD, Judge: Respondent, by separate notices, determined deficiencies in, and additions to, petitioner's Federal income taxes as follows:

Additions to Tax under I.R.C. Secs. 1

Yea…