Docket No. 8772-98.

80 T.C.M. 737 (2000)

T.C. Memo. 2000-359

Kenneth Andrew Baratelle v. Commissioner.

United States Tax Court.

Filed November 22, 2000.

Attorney(s) appearing for the Case

Kenneth Andrew Baratelle, pro se. Paul K. Voelker, for the respondent.


MARVEL, Judge:

Respondent determined a deficiency in petitioner's Federal income tax of $13,282 and an accuracy-related penalty, pursuant to section 6662(a),1 of $2,656 for 1994. Petitioner filed a petition seeking a redetermination of the deficiency and contesting his liability for the penalty.

Following concessions,2 the issues for decision are:

(1) Whether petitioner...

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