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JOSEPH P. v. COMMISSIONER

Docket No. 497-94.

71 T.C.M. 2089 (1996)

T.C. Memo. 1996-62

Joseph P. and Marilyn Schneller v. Commissioner.

United States Tax Court.

Filed February 15, 1996.

Attorney(s) appearing for the Case

Irwin G. Waterman and Michael T. Hymson, for the petitioners. Martha Sullivan, Jack A. Joynt, and William C. Shouse, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1990 in the amount of $138,748 and an accuracy-related penalty pursuant to section 6662(a) in the amount of $26,676 for such year.1 Respondent reflected this determination in a notice of deficiency dated October 13, 1993.

The principal unagreed item involves respondent's determination that petitioners...

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