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MONTALBANO v. COMMISSIONER

Dkt. No. 13873-05.

94 T.C.M. 499 (2007)

T.C. Memo. 2007-349

Carmelo Montalbano v. Commissioner.

United States Tax Court.

November 26, 2007.

Attorney(s) appearing for the Case

James A. Bruton III and Stephen A. Beck, for petitioner.

Scott A. Hovey, for respondent.

MEMORANDUM OPINION

THORNTON, Judge.

This case is before us on the parties' cross-motions for summary judgment. The sole issue for decision is whether petitioner is liable for the section 6663 fraud penalty for 1994.1 When the petition was filed, petitioner resided in Florida.2

Background

On January 18, 2000, a Federal grand jury in the U.S. District Court for the District...

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