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PAYNE v. COMMISSIONER

Dkt. No. 6311-03.

89 T.C.M. 1391 (2005)

T.C. Memo. 2005-130

Wayne Payne and Dorene J. Payne v. Commissioner.

United States Tax Court.

May 31, 2005.

Attorney(s) appearing for the Case

Thomas E. Brever, for petitioners.

David W. Sorensen, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge.

Respondent determined deficiencies in petitioners' 1993, 1994, and 1995 Federal income taxes of $29,881, $81,985, and $45,222, respectively. Respondent also determined that petitioners were liable for fraud penalties under section 66631 for 1993, 1994, and 1995 of $22,410, $61,488.75, and $33,916.50, respectively. The issues for decision are:

(1) Did respondent issue...

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