PICARD v. COMMISSIONER

Docket No. 2768-95.

74 T.C.M. 83 (1997)

T.C. Memo. 1997-320

James A. Picard v. Commissioner.

United States Tax Court.

Filed July 9, 1997.


Attorney(s) appearing for the Case

Martin J. Tierney and D. Dewey Watson, San Francisco, Calif., for the petitioner. Kevin G. Croke, for the respondent.


MEMORANDUM OPINION

GALE, Judge:

Respondent determined a deficiency of $3,169 in petitioner's 1992 Federal income tax and an addition to tax pursuant to section 6651(a)1 of $782.25. This case was submitted to the Court full stipulated pursuant to Rule 122. After concessions,2 the remaining issue for decision is whether payments made to petitioner by the City of Oakland during the year in issue pursuant...

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