United States Tax Court March 10, 2004, No. 14225-01 (Tonitis v. Comm'r)

T.C. Memo. 2004-60

UNITED STATES TAX COURT

EDWARD D. TONITIS, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 14225-01. Filed March 10, 2004.

William Randolph Klein, for petitioner.

Lorianne D. Masano, for respondent.

MEMORANDUM OPINION

COHEN, Judge: Respondent determined deficiencies and

additions to tax as follows:

Additions to Tax, I.R.C.

Year Deficiency Sec. 6651(f) Sec.