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TABREZI v. COMMISSIONER

Dkt. No. 5213-04.

91 T.C.M. 953 (2006)

T.C. Memo. 2006-61

Mazhar Tabrezi, f.k.a. Agha Hussain, and Sajida Razvi v. Commissioner.

United States Tax Court.

March 30, 2006.

Attorney(s) appearing for the Case

Richard D. Grossman, for petitioners;

Kathleen C. Schlenzig, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

Respondent determined a deficiency in petitioners' 2001 Federal income tax of $43,829 and an accuracy-related penalty of $8,765 pursuant to section 6662(a).1 After concessions,2 the remaining issues for decision are: (1) Whether respondent has the burden of proof in this case under Rule 142(a); (2) whether petitioners must recognize cancellation of indebtedness (COD...

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