CHENG v. COMMISSIONER

Dkt. No. 15027-02.

91 T.C.M. 1010 (2006)

T.C. Memo. 2006-74

Tommy Ho Ching Cheng v. Commissioner.

United States Tax Court.

April 12, 2006.


Attorney(s) appearing for the Case

David C. Holtz and Steven R. Mather, for petitioner;

Alan H. Cooper, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined a deficiency in petitioner's 1996 Federal income tax of $459,500 and an addition to tax under section 6651(f) of $344,625.1 The issues for decision are: (1) Whether the Court should reconsider its denial of petitioner's fourth motion for continuance; (2) whether the statute of limitations under section 6501(a) bars the issuance of a notice of deficiency...

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