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BALABANIAN v. COMMISSIONER

Docket No. 15947-95.

74 T.C.M. 1439 (1997)

T.C. Memo. 1997-565

Sarkis N. and Baka S. Balabanian v. Commissioner.

United States Tax Court.

Filed December 23, 1997.

Attorney(s) appearing for the Case

Richard P. Slivka, Denver, Colo., and Charles D. Henson, for the petitioners. Virginia L. Hamilton, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a $189,212 income tax deficiency and a $37,842 penalty under section 66621 for petitioners' 1990 taxable year. The issues2 presented for our consideration are: (1) Whether respondent correctly reconstructed petitioners' income by use of the bank deposits method, and (2) whether petitioners are liable for a penalty under section...

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