T.C. Memo. 1998-410
UNITED STATES TAX COURT
DAVID WHITE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19412-97. Filed November 13, 1998.
David White, pro se.
Melanie R. Urban, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent's motion for summary judgment under Rule 1211 and to
impose a penalty under section 6673. Respondent determined a
deficiency of $26,806, an addition to tax of $6,702 under section
1 All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the year in issue.
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