T.C. Memo. 2006-269
UNITED STATES TAX COURT
FREDERIC W. THRANE, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7367-04. Filed December 18, 2006.
Robert J. Gumser, for petitioner.
Michael S. Hensley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined an income tax deficiency
of $80,922 and a section 6662(a)1 accuracy-related penalty of
$14,918 with respect to petitioner's 2001 taxable year. After
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986 as in effect for the taxable
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
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