Ames D. Ray v. Commissioner

T.C. Memo. 2019-36

UNITED STATES TAX COURT AMES D. RAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14052-16. Filed April 15, 2019. J. Winston Krause, for petitioner. Donald D. Priver and Brock E. Whalen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION NEGA, Judge: Respondent determined a deficiency in petitioner’s Federal income tax and an accuracy-related penalty under section 6662(a)1 for tax year 1 Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the year at issue, and Rule references are to the Tax…