T.C. Memo. 2003-149
UNITED STATES TAX COURT
DAVID J. EDWARDS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 7010-00. Filed May 22, 2003.
Noel W. Spaid, for petitioner.
Dale A. Zusi, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
BEGHE, Judge: This case has remained before the Court to
consider the amount of the penalty under section 6673(a)(1)1
*This Supplemental Memorandum Opinion supplements Edwards
v. Commissioner, T.C. Memo. 2002-169.
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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