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BAILEY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 3080-08, 3081-08

T.C. Memo. 2012-96

F. LEE BAILEY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. F. LEE BAILEY AND ESTATE OF PATRICIA S. BAILEY, F. LEE BAILEY, PERSONAL REPRESENTATIVE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 2, 2012.

Attorney(s) appearing for the Case

F. Lee Bailey , for himself.

Carina J. Campobasso , Thomas R. Thomas , Frances F. Regan , and Janet F. Appel , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GUSTAFSON, Judge:

The Internal Revenue Service ("IRS") issued to petitioner F. Lee Bailey1 two statutory notices of deficiency on November 6, 2007, pursuant to section 6212,2 showing the IRS's determinations of the following deficiencies in income tax and failure-to-file additions to tax and accuracy-related penalties under sections 6651(a)(1) and 6662, respectively...

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