BOWEN v. COMMISSIONER

Docket Nos. 13714-99, 13723-99, 13724-99.

81 T.C.M. 1216 (2001)

T.C. Memo. 2001-47

Walter O. Bowen and Susan M. Bowen, et al. v. Commissioner.

United States Tax Court.

Filed February 27, 2001.


Attorney(s) appearing for the Case

Edward G. Marshall, for the petitioners.

Fred E. Green, Jr., for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

In separate notices of deficiency, respondent determined the following income tax deficiencies and penalties with respect to petitioners' Federal income tax returns for the taxable year 1995:2

     Walter O. Bowen & Susan M. Bowen, Docket No. 13714-99

               Deficiency       Sec. 6662(a) penalty

               $205,316  ...

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