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CADWELL v. COMMISSIONER

Docket No. 15456-08.

136 T.C. 38 (2011)

G. MASON CADWELL, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 3, 2011.

Attorney(s) appearing for the Case

Richard H. Morton and Kevin J. Ryan , for petitioner.

Kathleen Tagni , Sherri Wilder , and Betty Clary (specially recognized), for respondent.

OPINION

WELLS, Judge:

This case is before the Court on petitioner's motion for summary judgment and respondent's cross-motion for summary judgment pursuant to Rule 121.1 Respondent determined a deficiency of $33,057 in petitioner's Federal income tax for tax year 2004 and a penalty pursuant to section 6662(a) of $6,611. On August 31, 2009, petitioner filed a motion for summary judgment. On October 5, 2009, respondent filed...

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