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FILIOS v. COMMISSIONER

Docket No. 15719-96.

77 T.C.M. 1589 (1999)

T.C. Memo. 1999-92

Louis A. Filios and Estate of Emma L. Filios, Deceased, Louis A. Filios, Executor v. Commissioner.

United States Tax Court.

Filed March 25, 1999.

Attorney(s) appearing for the Case

Lawrence J. Casey, Scott E. Bettencourt, and John P. Ockerbloom, for the petitioners. Melanie M. Garger, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' 1992 and 1993 Federal income tax and an accuracy-related penalty as follows:

                  Penalty under
Year   Deficiency   Sec. 6662

1992    $194,121     $38,824
1993     133,807      26,761

After concessions, the issues for decision are:

1. Whether petitioner operated his horse racing...

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