Legal Opinion

Frankel v. Commissioner

United States Tax Court

Decided January 25, 1989No. Docket No. 5077-86UnpublishedCited by 2 opinions

1Opinion of the Court

RUSSELL M. FRANKEL AND JULIA A. FRANKEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Frankel v. Commissioner

Docket No. 5077-86.

United States Tax Court

T.C. Memo 1989-39; 1989 Tax Ct. Memo LEXIS 36; 56 T.C.M. (CCH) 1156; T.C.M. (RIA) 89039;

January 25, 1989.

George W. Connelly, Jr. and Harold A. Chamberlain, for the petitioners.

Marion S. Friedman and Marilyn S. Ames, for the respondent.

GOFFE

MEMORANDUM FINDINGS OF FACT AND OPINION

GOFFE, Judge: The Commissioner determined deficiencies in petitioners' Federal income taxes for the following taxable years:

Taxable Year

Petitioner(s)

Deficie…

2Cases cited5 opinions

  1. King v. CommissionerUnited States Tax Court · 1987
  2. Kemon v. CommissionerUnited States Tax Court · 1951
  3. Vickers v. CommissionerUnited States Tax Court · 1983
  4. Hall v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Commissioner of Internal Revenue v. StevensCourt of Appeals for the Second Circuit · 1935

3Cited by2 opinions

  1. Bielfeldt v. CommissionerUnited States Tax Court · 1998
  2. Pacific Sec. v. CommissionerUnited States Tax Court · 1992

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