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TONEY v. COMMISSIONER

Docket No. 10683-01.

86 T.C.M. 678 (2003)

T.C. Memo. 2003-333

John R. Toney v. Commissioner.

United States Tax Court.

Filed December 4, 2003.

Attorney(s) appearing for the Case

John R. Toney, pro se.

Robert S. Scarbrough, for the respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before the Court on respondent's motion for summary judgment. The issues for decision are: (1) Whether petitioner is liable for a deficiency of $14,6111 in his 1986 Federal income taxes; (2) whether petitioner is liable for additions to tax under section 6653(b)(1);2 and (3) whether petitioner is liable for the addition to tax under section 6661.

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