T.C. Memo. 2006-11
UNITED STATES TAX COURT
MICHAEL W. ALLEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20970-03. Filed January 25, 2006.
Michael W. Allen, pro se.
David L. Zoss, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies and
penalties with respect to petitioner’s income taxes for 1999,
2000, and 2001 (the years at issue). For 1999, respondent
determined a $12,769.70 deficiency and determined petitioner was
liable for a $2,273.94 accuracy-related penalty under section
6662.1 For 2000, respondent determined a $9,503 deficiency and
1All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
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