GARAVAGLIA v. COMMISSIONER OF INTERNAL REVENUE

Nos. 2500-07, 14693-09

T.C. Memo. 2011-228

CHARLES L. GARAVAGLIA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. MARY ANN T. GARAVAGLIA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 26, 2011.


Attorney(s) appearing for the Case

Joseph Falcone and Fred A. Foley , for petitioners.

Alexandra E. Nicholaides , John J. Comeau , and Robert M. Romashko , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

These consolidated cases concern the 1989 and 1990 Federal income taxes of Charles L. Garavaglia (Mr. Garavaglia) and Mary Ann T. Garavaglia (Ms. Garavaglia) (collectively, the Garavaglias or petitioners). Respondent determined deficiencies in Mr. Garavaglia's 1989 and 1990 Federal income taxes of $97,070 and $114,435 and fraud penalties under section 6663(a) of $72,803 and $85,826, respectively.

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