T.C. Memo. 2006-168
UNITED STATES TAX COURT
MARK SPITZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4075-05. Filed August 15, 2006.
Don Paul Badgley and Brian Gary Isaacson, for petitioner.
Kirk M. Paxson and Julie L. Payne, for respondent.
MEMORANDUM OPINION
HAINES, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes of $183,743 and $76,227 as well
as additions to tax under section 6662 of $36,749 and $15,245
for 2000 and 2001 (years at issue), respectively.1
1 Unless otherwise indicated, all section references are to
(continued...)
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