NOT FOR PUBLICATION
MEMORANDUM*
Joseph R. Banister appeals pro se from the Tax Court's decision, following a bench trial, upholding the Commissioner's determination of deficiencies and additions for tax years 2003 through 2006, and imposing a penalty under 26 U.S.C. § 6673. We have jurisdiction under 26 U.S.C. § 7482(a). We review de novo the Tax Court's legal conclusions and for clear error its factual findings...
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