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COWAN v. COMMISSIONER

Docket No. 23292-94.

71 T.C.M. 2649 (1996)

T.C. Memo. 1996-161

Ted Cowan v. Commissioner.

United States Tax Court.

Filed March 28, 1996.

Attorney(s) appearing for the Case

Ted Cowan, pro se. Julie L. Payne, for the respondent.

MEMORANDUM OPINION

DINAN, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1989 Federal income tax in the amount of $1,249 and an addition to tax pursuant to section 6651(a) in the amount of $312.25.

The issues for decision are: (1) Whether petitioner is liable for Federal income tax on the proceeds...

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