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Get T.C. Memo 2013-75 2013-2024

Taylor and Peter T. McCary, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: In a notice of deficiency issued to petitioner on August 26, 2011, respondent determined deficiencies in petitioner s Federal income tax of $48,946 and $6,522 for 2004 and 2005, respectively, and additions to tax under -2 *2 sections 6651(a)(1)1 and (2) and 6654 for 2004 and 2005. The issues for decision are: (1) whether petitioner failed to report gross receipts of $155,227 and $28,815 on.

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