Gary A. Wolens v. Commissioner

T.C. Memo. 2017-236

UNITED STATES TAX COURT GARY A. WOLENS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10853-15. Filed November 27, 2017. Anson H. Asbury, for petitioner. Ashley Y. Smith, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PUGH, Judge: In a notice of deficiency dated February 5, 2015, respondent determined that petitioner had a deficiency of $183,864 for the 2009 tax year.1 1 All section references are to the Internal Revenue Code in effect for the year(s) in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure,…