OCEAN PINES ASSOCIATION, INC. v. COMMISSIONER

OPINION

MORRISON, Judge:

On November 29, 2007, respondent Commissioner of Internal Revenue mailed a notice of deficiency for the taxable years 2003 and 2004 to petitioner Ocean Pines Association, Inc. We refer to respondent as the IRS. We refer to petitioner as the Association. In the notice, the IRS determined the following deficiencies in income tax and additions to tax under section 6651(a)(1):1

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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