Adams v. Comm'r

WILLIAM P. ADAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Adams v. Comm'r

Docket No. 23659-07

United States Tax Court

T.C. Memo 2013-7; 2013 Tax Ct. Memo LEXIS 9; 105 T.C.M. (CCH) 1029;

January 10, 2013, Filed

Decision will be entered under Rule 155.

Anthony V. Diosdi, for petitioner.

Shannon F. Edelstone, for respondent.

MORRISON, Judge.

MORRISON

MEMORANDUM FINDINGS OF FACT AND OPINION

MORRISON, Judge: The respondent (the IRS) issued a notice of deficiency for the year 2004 to the petitioner, William Adams, determining:

• a $207,598 income-tax deficiency,

• a $45,179.55 addition to tax…