WFO CORPORATION, ET AL. v. COMMISSIONER

Docket Nos. 6913-02, 6914-02, 6915-02, 6916-02.

88 T.C.M. 130 (2004)

T.C. Memo. 2004-186

WFO Corporation, et al. v. Commissioner.

United States Tax Court.

August 19, 2004.


Attorney(s) appearing for the Case

Terence J. Wolfe and Giselle M. Wolfe, pro sese.

Giselle M. Wolfe (an officer), for petitioner WFO Corporation; Stephen J. Neubeck and John A. Freeman, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION1

GALE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes, additions to tax, and penalties for the tax years 1994, 1995, 1996, and 1997 as follows:2

                    WFO Corp.
                 docket No. 6913-02

                              Accuracy-related
                                Penalties...

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