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REMLER v. COMMISSIONER

Docket No. 21868-03.

90 T.C.M. 502 (2005)

T.C. Memo. 2005-265

Michael Paul Remler and Pauline M. Velez v. Commissioner.

United States Tax Court.

November 17, 2005.

Attorney(s) appearing for the Case

Michael Paul Remler and Pauline M. Velez, pro sese;

Anthony J. Kim, Aaron Stonecash, and Paul R. Zamolo, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $8,546 and $4,750 for 1999 and 2000, respectively. Respondent also determined a section 6662(a) penalty for 2000.1 After concessions,2 the issues for decision are: (1) Whether petitioners' special education activity was engaged in for profit during 1999 and 2000 (years in...

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