ROGERS v. COMMISSIONER

Docket No. 13428-02.

90 T.C.M. 430 (2005)

T.C. Memo. 2005-248

Dennis L. Rogers and Charlotte Rogers v. Commissioner.

United States Tax Court.

October 26, 2005.


Attorney(s) appearing for the Case

Dana R. Taylor, for petitioners.

Kelley A. Blaine and Robert V. Boeshaar, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' income tax of $186,536 for 1997 and $269,225 for 1998 and that petitioners are liable for the addition to tax for late filing under section 6651(a)(1)1 of $45,384 for 1997 and $66,056.25 for 1998 and the accuracy-related penalty under section 6662(a) of $37,307.20 for 1997 and $53,845 for 1998.

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