WILLIAM C. v. COMMISSIONER

Dkt. No. 12065-05.

93 T.C.M. 1371 (2007)

T.C. Memo. 2007-154

William C. and Dorothy M. Smith v. Commissioner.

United States Tax Court.

June 14, 2007.


Attorney(s) appearing for the Case

John P. Konvalinka and Richard G. Pearce, Jr., for petitioners.

Travis T. Vance III and Monica D. Armstrong, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes of $8,779, $9,835, and $15,498 and penalties pursuant to section 6662(a) of $1,755.80, $1,967, and $3,099.60 for the years 2000, 2001, and 2002, respectively.1 The issues presently before the Court for decision are:

1. Whether petitioner Dorothy M. Smith's direct marketing activities were conducted...

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