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BALLMER v. COMMISSIONER

Dkt. No. 11370-05.

94 T.C.M. 338 (2007)

T.C. Memo. 2007-295

Paul E. Ballmer v. Commissioner.

United States Tax Court.

September 27, 2007.

Attorney(s) appearing for the Case

Derek L. Tabone, for petitioner.

Ron S. Chun, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

This petition arises from petitioner Paul E. Ballmer's receipt of $337,122.53 in the 2001 tax year from a lawsuit he filed against the California Franchise Tax Board (FTB). Respondent determined a deficiency of tax of $109,215, an addition to tax under section 6651(a)(1)1 of $27,303.75, and an addition to tax under section 6654(a) of $4,364.63 for petitioner's 2001 tax year...

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