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MUHICH v. COMMISSIONER

Docket Nos. 21561-97, 21562-97.

77 T.C.M. 2143 (1999)

T.C. Memo. 1999-192

Frank and Virginia Muhich v. Commissioner. Midwest Portraits Corp. v. Commissioner.

United States Tax Court.

Filed June 14, 1999.

Attorney(s) appearing for the Case

Jennifer Prager Sodaro and Joe Alfred Izen, Jr., for the petitioners. William T. Derick and Luanne S. DiMauro, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

These cases are before the Court consolidated for purposes of trial, briefing, and opinion. Frank and Virginia Muhich (the Muhichs) and Midwest Portraits Corp. (Midwest) separately petitioned the Court to redetermine respondent's determinations of the following deficiencies and accuracy-related penalties under section 6662(a):

Frank and Virginia Muhich, Docket No. 21561-97 
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