T.C. Memo. 2005-6
UNITED STATES TAX COURT
WINSTON KNAUSS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 12878-01, 7328-02. Filed January 18, 2005.
F. Pen Cosby, for petitioner.
Ronald T. Jordan and Angela J. Kennedy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: By notice of deficiency dated August 10, 2001,
respondent determined an income tax deficiency and fraud penalty
under section 6663(a)1 with regard to petitioner’s 1997 taxable
year. By notice of deficiency dated January 23, 2002, respondent
1 Unless otherwise noted, all section references are to the
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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