T.C. Memo. 2006-129
UNITED STATES TAX COURT
DIANA COTE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12502-04. Filed June 21, 2006.
Philip A. Putman, for petitioner.
Gavin L. Greene, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax of $176,428 for 1999 and
additions to tax of $55,249.74 under section 6651(a) and
$6,479.40 for failure to pay estimated tax under section 6654.1
1 Section references are to the applicable versions of the
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