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RICHARDSON v. COMMISSIONER

Dkt. Nos. 16794-03, 16795-03.

91 T.C.M. 981 (2006)

T.C. Memo. 2006-69

Homer L. Richardson v. Commissioner. Gloria M. Richardson v. Commissioner.

United States Tax Court.

April 11, 2006.

Attorney(s) appearing for the Case

Robert Alan Jones, for petitioners.

Richard J. Hassebrock and John A. Freeman, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

Respondent determined the following deficiencies and penalties with respect to petitioners' Federal income taxes for the 1996 and 1997 taxable years:1

Homer L. Richardson — Docket No. 16794-03

                               Penalties
Year     Deficiency     Sec. 6662     Sec. 6663
1996      $164,442        $67...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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