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O'MALLEY v. COMMISSIONER

Docket No. 15051-89.

96 T.C. 644 (1991)

THOMAS O'MALLEY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 15, 1991.

Attorney(s) appearing for the Case

Patrick J. Calihan and Edward J. Calihan, Jr., for the petitioner.

James S. Stanis and Don M. Parkinson, for the respondent.

HAMBLEN, Judge:

Respondent determined deficiencies in excise tax against petitioner in the amounts of $13,314, $24,491, $24,491, and $24,491 for the taxable years 1981, 1982, 1983, and 1984, respectively. After concessions by respondent, the sole issue for decision is whether Thomas O'Malley (hereinafter petitioner) is subject to the excise tax imposed under section 4975(a)1 for each of the taxable years at issue.

FINDINGS...

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