William Ray Smith, (1998)

Extract

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William Ray Smith, (1998)

T.C. Memo. 1998-148

UNITED STATES TAX COURT WILLIAM RAY SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20916-95. Filed April 23, 1998.

William Ray Smith, pro se. Kathey Shaw, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined deficiencies in, and additions to tax on, petitioner's Federal income tax for the taxable years 1992, 1993, and 1994 as follows:

Additions to Tax Year Deficiency Sec. 6651(a)(1) 1992 $4,073 $1,018

1993 4,219 1,054

1994 4,368 1,092

After concessions by the parties, the issues for decision are: (1) Whether, for income tax purposes, petitioner, who specifically bargained to be paid in American Eagle gold coins (the gold coins) ...

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