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MALBY v. COMMISSIONER

Docket Nos. 1155-89, 11453-89.

62 T.C.M. 343 (1991)

T.C. Memo. 1991-364

Raymond Malby v. Commissioner.

United States Tax Court.

Filed August 6, 1991.

Attorney(s) appearing for the Case

Kevin J. Mirch, 445 Apple St., Reno, Nev., for the petitioner. David W. Sorensen, for the respondent.

Memorandum Opinion

GUSSIS, Special Trial Judge:

These consolidated cases were heard pursuant to the provisions of section 7443A(b) of the Code and Rule 180 et seq.1

Respondent determined deficiencies in petitioner's Federal income taxes for the tax years ended 1985 and 1986 in the amounts of $1,268 and $509, respectively. Respondent also determined that petitioner was liable for the addition to tax under section 6651...

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