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AVERY v. COMMISSIONER

Dkt. No. 17314-05.

93 T.C.M. 1002 (2007)

T.C. Memo. 2007-60

Nathaniel Caleb Avery v. Commissioner.

United States Tax Court.

March 14, 2007.

Attorney(s) appearing for the Case

Peter J. Gibbons, for petitioner.1

Michele Craythorn, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Respondent determined a $39,890 deficiency in petitioner's 2002 Federal income tax and additions to tax of $6,743.70 under section 6651(a)(1), $4,046.22 under section 6651(a)(2), and $964.76 under section 6654.2 After concessions by respondent,3 the issues for decision are:

(1) Whether payroll summaries of petitioner's employer are admissible...

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