SANDERS v. COMMISSIONER

Docket No. 25134-96.

90 T.C.M. 6 (2005)

T.C. Memo. 2005-163

Eugene A. Sanders, v. Commissioner.

United States Tax Court.

July 5, 2005.


Attorney(s) appearing for the Case

Douglas Alan Azar, for petitioner.

Nhi T. Luu-Sanders, for respondent.


MEMORANDUM OPINION

CARLUZZO, Special Trial Judge:

In what is commonly referred to as an affected item notice of deficiency, respondent determined a section 6662(a)1 accuracy-related penalty of $8,411 (amounts are rounded) with respect to petitioner's 1991 Federal income tax. The issue for decision is whether the underpayment of tax required to be shown on petitioner's 1991 Federal income tax return is due to negligence or intentional...

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