Garfield v. Commissioner

SUMMARY ORDER

Nathaniel Garfield and his wife, Carol Garfield, with whom he jointly filed tax returns during the relevant years, appeal from a judgment of the Tax Court (Foley, J.), entered December 18, 2006, 2006 WL 8724941, which sustained the Commissioner’s assessment of both a deficiency and an accuracy-related penalty. We assume the parties’ familiarity with the underlying facts, the procedural history, and the issues on appeal. We review the Tax Court’s findings of fact for clear error, see Am. Valmar Int’l Ltd. v. Comm’r, 229 F.3d 98, 101 (2d Cir.2000), and its legal determinations de…