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ARBERG v. COMMISSIONER

Dkt. No. 15376-05.

94 T.C.M. 215 (2007)

T.C. Memo. 2007-244

Lee B. Arberg And Melissa A. Quinn v. Commissioner.

United States Tax Court.

August 27, 2007.

Attorney(s) appearing for the Case

Roger D. Lorence, for petitioners.

Stephen R. Takeuchi, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

Respondent determined a Federal income tax deficiency for petitioners' 2000 taxable year in the amount of $167,221 and a penalty pursuant to section 6662(a) in the amount of $33,444.1 After concessions, the principal issues for decision are:

(1) Whether petitioners are entitled to report claimed gains and losses in ordinary income on account of an alleged business...

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