T.C. Memo. 2004-71
UNITED STATES TAX COURT
B. SURI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11380-02. Filed March 18, 2004.
B. Suri, pro se.
Gerard Mackey, for respondent.
MEMORANDUM OPINION
COHEN, Judge: Respondent determined a deficiency of
$169,586 in petitioner’s Federal income taxes for 1999 and
additions to tax under sections 6651(a)(1), 6651(a)(2), and
6654(a). After concessions, respondent now asserts that
petitioner has a deficiency in income tax for 1999 of $24,860 and
is liable for an addition to tax under section 6651(a)(1) of
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