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LEROY v. COMMISSIONER

Docket No. 9198-00.

82 T.C.M. 712 (2001)

T.C. Memo. 2001-264

Leroy and Shirley Combs v. Commissioner.

United States Tax Court.

Filed October 3, 2001.

Attorney(s) appearing for the Case

Leroy and Shirley Combs, pro sese. Dale A. Zusi, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice dated May 24, 2000, respondent determined a $298,992 deficiency, a $74,598 section 6651(a) addition to tax, and a $59,798 section 6662(a) penalty relating to petitioners' 1994 Federal income tax. All section references are to the Internal Revenue Code in effect for the year in issue. The issues for decision are whether petitioners failed to report income for 1994 and are liable for a section...

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