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WOLCOTT v. COMMISSIONER

Dkt. Nos. 4371-06, 4372-06.

94 T.C.M. 400 (2007)

T.C. Memo. 2007-315

Stanley C. Wolcott v. Commissioner.

United States Tax Court.

October 18, 2007.

Attorney(s) appearing for the Case

Stanley C. Wolcott, pro se.

Beth A. Nunnink, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

These consolidated cases are before the Court on petitions for judicial review of statutory notices of deficiency dated November 28, 2005. After concessions,1 the issues for decision are:

(1) Whether petitioner is liable for additions to tax under sections 6651(a)(1) and (2) and 6654(a) for the two taxable years at issue;2 and

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