Homero F. Meruelo v. Commissioner

T.C. Memo. 2018-16

UNITED STATES TAX COURT HOMERO F. MERUELO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1795-13. Filed February 5, 2018. Howard W. Gordon, Leticia Vega, and Alyssa R. Wan, for petitioner. W. Robert Abramitis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: The Internal Revenue Service (IRS or respondent) deter- mined a deficiency of $2,600,275 in petitioner’s Federal income tax for 2005.1 1 All statutory references are to the Internal Revenue Code (Code) in effect for the years at issue, and all Rule references are to the Tax…