T.C. Memo. 2004-138 UNITED STATES TAX COURT JAMES DIRKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6867-03. Filed June 10, 2004. Michael P. Casterton, for petitioner. Kathryn K. Vetter, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioner petitioned the Court to redetermine a $44,097 deficiency in his 2000 Federal income tax and an $8,819 accuracy-related penalty under section 6662(a) and (d) for substantial understatement of income tax.1 We decide whether 1 Unless otherwise noted, section references are to the (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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