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BHATTACHARYYA v. COMMISSIONER

Dkt. No. 15024-04.

93 T.C.M. 711 (2007)

T.C. Memo. 2007-19

Bidyut K. Bhattacharyya and Diana T. Bhattacharyya v. Commissioner.

United States Tax Court.

January 30, 2007.

Attorney(s) appearing for the Case

Bidyut K. Bhattacharyya and Diana T. Bhattacharyya, pro sese.

Wesley F. McNamara, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined a deficiency in petitioners' 2000 Federal income tax of $314,372 and an addition to tax under section 6651(a)(1) of $38,837.1 After concessions,2 the issues for decision are: (1) Whether respondent's and petitioners' motions to conform pleadings to the evidence should be granted; (2) whether petitioners received but failed...

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