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
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