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SWIATEK v. COMMISSIONER

Docket No. 10978-97.

78 T.C.M. 223 (1999)

T.C. Memo. 1999-257

Harold F. and Barbara J. Swiatek v. Commissioner.

United States Tax Court.

Filed August 4, 1999.

Attorney(s) appearing for the Case

Harold F. Swiatek and Barbara J. Swiatek, pro sese. Deborah Stanley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $95,283 and a section 6662 accuracy-related penalty in the amount of $19,057.

The dispute in this case centers on respondent's determination that petitioners had $295,315 of unreported income in 1991, and that $271,836 of this amount is attributable to payments Harold F. Swiatek (petitioner) received from...

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