HANSEN v. COMMISSIONER

Docket No. 25191-96.

88 T.C.M. 504 (2004)

T.C. Memo. 2004-269

Gary D. and Johnean F. Hansen v. Commissioner.

United States Tax Court.

November 24, 2004.


Attorney(s) appearing for the Case

Wendy S. Pearson, Terri A. Merriam, and Jennifer A. Gellner, for petitioners;

Nhi T. Luu Sanders, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GOLDBERG, Special Trial Judge:

Respondent determined that petitioners are liable for a section 6662(a) accuracy-related penalty of $1,545 for the taxable year 1991. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The sole issue for decision is whether petitioners are...

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