T.C. Memo. 2001-153
UNITED STATES TAX COURT
MICHAEL A. MCCANN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10416-99. Filed June 27, 2001.
Michael A. McCann, pro se.
Gordon P. Sanz and Lance Stodghill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of
$177,929 in petitioner’s Federal income tax for 1996 and a
penalty of $35,445 under section 6662(a). After concessions by
respondent, the amounts remaining in dispute are a deficiency of
approximately $40,000 and a penalty of approximately $8,000. The
issue for decision is whether petitioner is entitled to any
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