T.C. Memo. 2005-199
UNITED STATES TAX COURT
RUSSELL W. COULTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13661-03. Filed August 16, 2005.
Russell W. Coulton, pro se.
Linette B. Angelastro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined a deficiency of
$87,529 in petitioner’s Federal income tax for 2001, a $21,882.25
addition to tax under section 6651(a)(1)1 for failure to timely
file a return and a $3,497.97 addition to tax under section 6654
for failure to pay estimated income taxes for 2001. After
1All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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