HEWITT v. COMMISSIONER

Docket No. 17146-95.

109 T.C. 258 (1997)

JOHN T. AND LINDA L. HEWITT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 29, 1997.


Attorney(s) appearing for the Case

Neil L. Rose, Donna S. Rucker, and Robert E. Lee, for petitioners.

Deborah C. Stanley, for respondent.


OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and penalties under section 6662(a)1 as follows:

                                        Penalty
       Year        Deficiency         sec. 6662(a)

       1990         $17,332             $3,466
       1991          22,945              4,589

After concessions, the sole...

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