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EDWARDS v. COMMISSIONER

Docket No. 7010-00.

85 T.C.M. 1357 (2003)

T.C. Memo. 2003-149

David J. Edwards v. Commissioner.

United States Tax Court.

Filed May 22, 2003.

Attorney(s) appearing for the Case

Noel W. Spaid, for the petitioner.

Dale A. Zusi, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

BEGHE, Judge:

This case has remained before the Court to consider the amount of the penalty under section 6673(a)(1)1 that petitioner must pay respondent and the amount of respondent's costs under section 6673(a)(2) that petitioner's counsel, Noel W. Spaid, must pay respondent.

Background

This case was tried in 2001 over 2 days separated by more than 5 months. In Edwards...

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