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LANG v. COMMISSIONER

Docket No. 7280-97.

79 T.C.M. 2158 (2000)

T.C. Memo. 2000-188

Edward D. Lang and Sharon A. Lang v. Commissioner.

United States Tax Court.

Filed June 27, 2000.

Attorney(s) appearing for the Case

Kevin Phillip Kennedy, for the petitioners. T. Richard Sealy III, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $104,221 for 1989, $136,986 for 1990, $161,458 for 1991, $93,890 for 1992, and $76,200 for 1993. Respondent also determined that petitioners are liable for the fraud penalty under section 6663 for each year, but respondent now concedes they are not. Respondent determined in the alternative that petitioners

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