T.C. Memo. 2006-68
UNITED STATES TAX COURT
DANIEL C. McMANUS, Petitioner v. COMMISSIONER OF INTERNAL
REVENUE, Respondent
Docket Nos. 12336-04, 12711-04. Filed April 10, 2006.
Philip A. Putman, for petitioner.
Monica Gingras, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes for 2001 and 2002 (years at
issue) of $39,799 and $21,789, respectively, as well as additions
to tax under section 6651(a)(1) of $9,949 and $5,447, and
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