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SIDELL v. COMMISSIONER

Docket No. 10489-98.

78 T.C.M. 423 (1999)

T.C. Memo. 1999-301

Chester F. and Faye L. Sidell v. Commissioner.

United States Tax Court.

Filed September 9, 1999.

Attorney(s) appearing for the Case

David R. Andelman and Juliette Galicia Pico, for the petitioners. Mary P. Hamilton, David N. Brodsky, and Maura A. Sullivan, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined deficiencies and an accuracy-related penalty under section 6662(a) with respect to petitioners' Federal income taxes, as follows:

                                           Penalty
Year                      Deficiency     Sec. 6662(a)

1993 ..................     $103,728          --
1994...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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