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MASON v. COMMISSIONER

Docket No. 14102-02.

88 T.C.M. 398 (2004)

T.C. Memo. 2004-247

Ray E. Mason v. Commissioner.

United States Tax Court.

October 28, 2004.

Attorney(s) appearing for the Case

Kevin D. Watley and B. David Sisson, for petitioner.

William F. Castor, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined a deficiency of $3,2191 in petitioner's Federal income tax for 1995 and determined that petitioner was liable for the addition to tax of $2,414 under section 6651(f)2 for fraudulent failure to file a timely income tax return for 1995 and alternatively under section 6651(a)(1) for failure to file timely. After concessions...

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