KIKALOS v. COMMISSIONER

Docket. No. 11486-01.

87 T.C.M. 1146 (2004)

T.C. Memo. 2004-82

Nick Kikalos and Helen Kikalos v. Commissioner.

United States Tax Court.

Filed March 23, 2004.


Attorney(s) appearing for the Case

John J. Morrison, for the petitioners.

Ronald T. Jordan, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1997 of $105,296 and a penalty under section 6662(a)1 in the amount of $21,059.20. After concessions,2 the issues presented for our consideration are: (1) Whether petitioners' income was understated and (2) whether petitioners are subject to section 6662...

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