O'CONNOR v. COMMISSIONER

Docket No. 22345-97.

81 T.C.M. 1509 (2001)

T.C. Memo. 2001-90

Robert and Karen O'Connor v. Commissioner.

United States Tax Court.

Filed April 11, 2001.


Attorney(s) appearing for the Case

John L. Burghardt, for the petitioners.

Kathryn K. Vetter, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge.

In a notice of deficiency addressed to petitioners, respondent determined deficiencies and penalties as follows:

                                      Penalty
   Year               Deficiency    Sec. 6662(a)

   1993............... $114,257      $22,851
   1994...............  171,550       34,310
   1995...............  189,541       37,908

The...

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