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SHEA v. COMMISSIONER

Docket Nos. 2860-96, 2861-96.

79 T.C.M. 2112 (2000)

T.C. Memo. 2000-179

James P. Shea and Patricia H. Shea v. Commissioner. Christopher M. and Kim A. Shea v. Commissioner.

United States Tax Court.

Filed May 30, 2000.

Attorney(s) appearing for the Case

Joseph Falcone, Southfield, Michigan, for the petitioners. Timothy S. Murphy, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and penalties as follows:

  James P. Shea and Patricia H. Shea, Docket No.
                     2860-96

                                          Penalty
Year                        Deficiency   Sec. 66621

1992 ....................    $244,224...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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