T.C. Memo. 2003-194
UNITED STATES TAX COURT
EDWARD A. BOUGAS III, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13256-01. Filed July 2, 2003.
Edward A. Bougas III, pro se.
Steven W. Ianacone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioner’s Federal income tax for the taxable
year 1998 in the amount of $25,000. Unless otherwise indicated,
section references are to the Internal Revenue Code in effect for
the year at issue.
The issue for decision is whether petitioner is liable for
the 10-percent additional tax under section 72(t) on a $250,000
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