United States Tax Court December 5, 2016, Docket No. 13227-14. (Nwabasili v. Comm'r)

T.C. Memo. 2016-220

UNITED STATES TAX COURT

CHINWEIKE NWABASILI, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 13227-14. Filed December 5, 2016.

Chinweike Nwabasili, for himself.

Christopher M. Groboske, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MORRISON, Judge: The respondent (referred to here as the “IRS”) issued

a notice of deficiency to the petitioner, Mr.