Cecile Barker v. Commissioner

T.C. Memo. 2018-67

UNITED STATES TAX COURT CECILE BARKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21067-14. Filed May 21, 2018. Jose M. Ferrer and Jeffrey L. Rubinger, for petitioner. W. Robert Abramitis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PUGH, Judge: Respondent determined a deficiency of $1,807,886 in petitioner’s Federal income tax for 2011 and an addition to tax under section 6651 of $451,971.1 After concessions, the issues for decision are: (1) whether SoBe 1 Unless otherwise indicated, section references are to the Internal Revenue…