T.C. Memo. 2006-87
UNITED STATES TAX COURT
JOEL RAPPAPORT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10777-04. Filed April 25, 2006.
Martin A. Stoll, for petitioner.
Willie Fortenberry, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency of
$47,650 in petitioner’s Federal income tax for 2001 and additions
to tax (1) for failure to file under section 6651(a)(1)1 in the
1 Section references are to the Internal Revenue Code as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
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