T.C. Memo. 2006-259
UNITED STATES TAX COURT
WILLIAM LENIHAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13764-03. Filed December 5, 2006.
William Lenihan, pro se.
Frank J. Jackson and Michelle L. Maniscalco, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated May 20, 2003
(the notice), respondent determined a deficiency in petitioner’s
2000 Federal income tax of $26,436 and additions to tax of
$4,817, $2,248, and $1,121 under sections 6651(a)(1) and (2) and
6654(a), respectively. Petitioner assigned error to each of
those determinations. Respondent conceded the addition to tax
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