Russell v. Comm'r

PAMELA B. RUSSELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Russell v. Comm'r

Docket No. 24413-05

United States Tax Court

T.C. Memo 2011-81; 2011 Tax Ct. Memo LEXIS 80; 101 T.C.M. (CCH) 1363;

April 6, 2011, Filed

Decisions will be entered under Rule 155.

Mark E. Cedrone, for petitioner.

Jack T. Anagnostis, for respondent.

WELLS, Judge.

WELLS

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge: Respondent determined that petitioner was liable for a deficiency and additions to tax for failure to file timely pursuant to section 6651(a)(1) and failure to pay timely pursuant to section…