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STRONG v. COMMISSIONER

Docket No. 582-99.

81 T.C.M. 1557 (2001)

T.C. Memo. 2001-103

Gerald Dennis Strong v. Commissioner.

United States Tax Court.

Filed April 30, 2001.

Attorney(s) appearing for the Case

Gerald Dennis Strong, pro se.

Innessa Glazman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHABOT, Judge:

Respondent determined a deficiency in individual income tax and an addition to tax under section 6651(a)(1)1 (failure to timely file tax return) against petitioner for 1994 in the amounts of $108,941 and $5,573.85, respectively.

After a concession by respondent,2 the issues for decision are as follows:

(1) Whether under the doctrine...

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