T.C. Memo. 2005-234
UNITED STATES TAX COURT
WILLIAM A. EGAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4568-04. Filed October 5, 2005.
Peter B. Tiede, for petitioner.
Allison O. Woodbury, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined a $30,618 deficiency
in petitioner’s Federal income tax for 1998 and that petitioner
was liable for a $5,789 accuracy-related penalty for substantial
understatement under section 6662(a).1 After concessions,2 we
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.
2Petitioner conceded respondent’s disallowance of
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