Docket Nos. 142-95, 22884-95.

72 T.C.M. 1519 (1996)

T.C. Memo. 1996-549

Joseph and Annie Chu v. Commissioner.

United States Tax Court.

Filed December 18, 1996.

Attorney(s) appearing for the Case

John M. Youngquist, San Francisco, Calif., for the petitioners. Allan D. Hill, for the respondent.


LARO, Judge:

Docket Nos. 142-95 and 22884-95 are before the Court consolidated for purposes of trial, briefing, and opinion. Joseph Chu and Annie Chu petitioned the Court to redetermine respondent's determination of the following Federal income tax deficiencies and additions thereto:

Year                 Deficiency   Penalties Sec. 6662(a)

1990 .............    $193,739         ...

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