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SIMPSON v. COMMISSIONER

Docket No. 2832-01.

86 T.C.M. 470 (2003)

T.C. Memo. 2003-294

Randolph S. Simpson I v. Commissioner.

United States Tax Court.

Filed October 21, 2003.

Attorney(s) appearing for the Case

Randolph S. Simpson I, pro se.

Gordon P. Sanz, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

Respondent determined a deficiency of $4,453 in petitioner's Federal income tax for the year 1997. In an amendment to answer, respondent seeks to increase the deficiency by $5,012, for a total deficiency of $9,465.1

After a concession by petitioner,2 the issues for decision are: (1) Whether petitioner is liable for the 10-percent additional...

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