T.C. Memo. 2004-31                                   
                               UNITED STATES TAX COURT                                
                            PAUL R. PEETE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 16002-02.             Filed February 6, 2004.               
               Paul R. Peete, pro se.                                                 
               Jean Song, for respondent.                                             
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GOEKE, Judge:  Respondent determined a deficiency in                   
          petitioner’s 2000 Federal income tax of $20,015 and an accuracy-            
          related penalty under section 6662(a)1 of $3,659.80.  After                 
               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect during the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
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