T.C. Memo. 2006-74
UNITED STATES TAX COURT
TOMMY HO CHING CHENG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15027-02. Filed April 12, 2006.
David C. Holtz and Steven R. Mather, for petitioner.
Alan H. Cooper, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined a deficiency in
petitioner’s 1996 Federal income tax of $459,500 and an addition
to tax under section 6651(f) of $344,625.1 The issues for
1 Unless otherwise indicated, 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. Amounts
are rounded to the nearest dollar.
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