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DOWNING v. COMMISSIONER

Docket No. 12108-98.

86 T.C.M. 738 (2003)

T.C. Memo. 2003-347

Michael J. Downing and Sandra M. Downing v. Commissioner.

United States Tax Court.

Filed December 29, 2003.

Attorney(s) appearing for the Case

John S. Ponseti, for the petitioners.

Susan S. Canavello, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHABOT, Judge.

By separate notices of deficiency, respondent determined deficiencies in individual income tax and penalties under section 66631 (fraud) against petitioners as follows:

                                            Penalties
                       Year   Deficiency1   Sec. 6663

  Michael J. Downing
                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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