METALLIC v. COMMISSIONER

MEMORANDUM OPINION

COHEN, Judge.

This case is before the Court on respondent's Motion for Summary Judgment pursuant to Rule 121. Respondent determined deficiencies of $15,476, $7,639, and $17,408.10 in petitioner's Federal income taxes for 2001, 2002, and 2003, respectively. Respondent also determined additions to tax as follows:

      Year        Sec. 6651(a)(1)       Sec. 6651(a)(2)      Sec. 6654

      2001 ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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