T.C. Memo. 2006-15
UNITED STATES TAX COURT
ELIZABETH GILES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16640-03. Filed January 31, 2006.
B. Paul Husband, for petitioner.
Michael W. Berwind, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined deficiencies of
$7,117, $5,470, and $6,793 and accuracy-related penalties under
section 6662(a) for 1999, 2000, and 2001, respectively (years in
issue).1 After concessions,2 the issues for decision are:
1 Unless otherwise noted, all section references are to the
(continued...)
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