DAVID M. v. COMMISSIONER

Docket Nos. 555-00, 1821-00.

85 T.C.M. 1401 (2003)

T.C. Memo. 2003-152

David M. and Teri L. Saykally v. Commissioner. Computer Power Software Group, Inc. v. Commissioner.

United States Tax Court.

Filed May 27, 2003.


Attorney(s) appearing for the Case

Robert R. Rubin, for the petitioners.

Kathryn K. Vetter, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge.

These cases were consolidated by motion of the parties for purposes of trial, briefing, and opinion. In Docket No. 1821-00, respondent determined a deficiency in Federal income tax of $103,250 and a section 6662(a)1 accuracy-related penalty of $20,650 for the taxable year 1996 with respect to petitioner Computer Power Software Group, Inc. (CPSG, Inc.). In Docket No. 555-00...

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