WALLMEYER v. COMMISSIONER

Docket No. 10727-87.

59 T.C.M. 271 (1990)

T.C. Memo. 1990-166

Joseph B. Wallmeyer v. Commissioner.

United States Tax Court.

Filed March 28, 1990.


Attorney(s) appearing for the Case

Joseph B. Wallmeyer, pro se. John C. McDougal, for the respondent.


Memorandum Opinion

RUWE, Judge:

This matter is before the Court on respondent's motion for summary judgment. On December 1, 1986, a jeopardy assessment was made against petitioner for taxable years 1980, 1981, 1982, 1983, and 1984, pursuant to section 6861(a).1 In a notice of deficiency dated January 29, 1987, respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:

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