United States Tax Court November 8, 2010, Docket 4325-07 (Feller v. Commissioner)

combined-opinion

RICK D. FELLER, PETITIONER v. COMMISSIONER OF

INTERNAL REVENUE, RESPONDENT

Docket No. 4325–07. Filed November 8, 2010.

P overstated his prepayment credits on his Federal income

tax returns in order to claim refunds for 1992 through 1997.

On Nov. 22, 2006, R issued two notices of deficiency deter-

mining that P was subject to the fraud penalty of I.R.C. sec.