John M. Coleman v. Commissioner

T.C. Memo. 2020-146

UNITED STATES TAX COURT JOHN M. COLEMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19540-17. Filed October 22, 2020. John B. Magee and Eric J. Albers-Fiedler, for petitioner. William J. Gregg, Bartholomew Cirenza, and Ryan Z. Sarazin, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: Because petitioner did not file a Federal income tax re- turn for 2014, the IRS prepared a substitute for return (SFR) and issued him a no- tice of deficiency. The parties have settled all issues but two: (1) whether peti- tioner has…