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FLOOD v. COMMISSIONER

Docket No. 12279-98.

81 T.C.M. 1175 (2001)

T.C. Memo. 2001-39

Glenn H. and Diane J. Flood v. Commissioner.

United States Tax Court.

Filed February 21, 2001.

Attorney(s) appearing for the Case

Cheryl R. Frank and Gerald W. Kelly, Jr., for the petitioners.

David Delduco, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge.

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

                          Penalty
Year     Deficiency     Sec. 6662(a)

1991        $ 9,459        $1,892
1992          9,212         1,842
1993         23,323         4,665

The issues for our consideration are: (1) Whether petitioners...

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