T.C. Memo. 2004-175
UNITED STATES TAX COURT
KENNETH J. BARELA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3873-02. Filed July 28, 2004.
Kenneth J. Barela, pro se.
Frederick J. Lockhart, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Chief Judge: Respondent, for petitioner’s 1999
taxable year, determined a $49,703 income tax deficiency and
additions to tax under sections 6651(a)(1)1 and 6654 in the
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year at
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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