T.C. Memo. 2003-184
UNITED STATES TAX COURT
STEPHEN HAYDEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10441-01. Filed June 24, 2003.
Saul A. Bernick and Neal J. Shapiro, for petitioner.
Helen H. Keuning, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: Respondent determined deficiencies in
petitioner’s Federal income tax and additions to tax under section
6651(a)(1)1 for 1997 and 1998 as follows:
1 All section references are to the Internal Revenue Code
in effect for the years at issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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