DAVIS v. COMMISSIONER

Docket No. 7691-98.

79 T.C.M. 1730 (2000)

T.C. Memo. 2000-101

Harvey J. Davis and Patricia A. Davis v. Commissioner.

United States Tax Court.

Filed March 27, 2000.


Attorney(s) appearing for the Case

James F. McLeod, for the petitioners. C. Glenn McLoughlin and Brian A. Smith, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and a penalty under section 6662 as follows:

                                          Penalty
Year                        Deficiency   Sec. 6662

1994 ....................    $ 9,614      $1,914
1995 ....................     11,855       2,356
1996 ....................      9,956      ...

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