ALBER I. v. COMMISSIONER

Docket No. 11202-01.

85 T.C.M. 1353 (2003)

T.C. Memo. 2003-148

Alber I. and Georgette H. Said v. Commissioner.

United States Tax Court.

Filed May 22, 2003.


Attorney(s) appearing for the Case

Alber I. Said and Georgette H. Said, pro sese.

Nguyen-Hong Hoang, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined deficiencies in, and penalties on, petitioners' Federal income tax liabilities as follows:

                            Penalty, I.R.C.
       Year    Deficiency    Sec. 6663(a)

       1993    $ 41,582      $ 31,187
       1994      57,974        43,481
       1995     346,400       259,800

After concessions, the issues for...

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