T.C. Memo. 2007-10
UNITED STATES TAX COURT
RAYMOND A. HEERS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22338-03. Filed January 16, 2007.
George E. Harp, for petitioner.
William F. Castor, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax of $86,858 and additions to tax
under sections 6651(a)(1)1 and 6654 of $11,616.75 and $3,085.41,
1Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable year in issue,
and Rule references are to the Tax Court Rules of Practice and
(continued...)
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