On August 3, 2010, the respondent (the IRS) issued a notice of deficiency to the petitioner, Mr. Diep N. Hoang. The notice determined a deficiency of $5,188,587 in federal income tax for 2006, a section 6651(a)(1) addition to tax of $1,297,533.50, and a penalty under section 6662(a) of $1,037,717.40...
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