T.C. Memo. 2005-281
UNITED STATES TAX COURT
GLEN B. SILVER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15740-04. Filed December 5, 2005.
Glen B. Silver, pro se.
Kevin M. Murphy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of
$34,578.07 and $34,855 in petitioner’s Federal income taxes for
2001 and 2002, respectively. Respondent also determined that
petitioner was liable for additions to tax of $3,344.45 and
$1,666.11 under section 6651 and $426.25 and $217.06 under
section 6654 for those years, respectively. Because petitioner
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