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RUDMAN v. COMMISSIONER

Docket No. 3445-00.

118 T.C. 354 (2002)

118 T.C. No. 21

KEITH M. RUDMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 29, 2002.

Attorney(s) appearing for the Case

Harlan M. Ten Pas, for petitioner.

David S. Weiner, for respondent.

OPINION

SWIFT, Judge:

For 1994, respondent determined a deficiency in petitioner's Federal income tax and an accuracy-related penalty as follows:

                                       Accuracy-related
                                           penalty
  Year             Deficiency            sec. 6662(a)

  1994              $312,026               $57,203...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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