T.C. Memo. 2007-166
UNITED STATES TAX COURT
STEPHEN S. ZIEGLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23638-04. Filed June 27, 2007.
Michael J. Grace, for petitioner.
Roger W. Bracken, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
ciencies in, additions under section 6651(a)(1)1 to, and
accuracy-related penalties under section 6662(a) on petitioner’s
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the years at
issue. All Rule references are to the Tax Court Rules of Prac-
tice and Procedure.
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Last modified: November 10, 2007