T.C. Memo. 2006-82
UNITED STATES TAX COURT
HARVEY L. HOOVER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 15557-99, 4590-00L. Filed April 24, 2006.
Harvey L. Hoover, pro se.
Diane L. Worland, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: These cases were consolidated for purposes of
trial, briefing, and opinion. On August 20, 1999, respondent
issued a notice of deficiency, which determined deficiencies and
penalties with respect to petitioner’s Federal income taxes as
follows:
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