POSNER, Circuit Judge.
The Tax Court ruled that the petitioners, a married couple filing a joint return, had underpaid federal income tax for 2005 by $8,553. The court assessed a deficiency equal to that amount and tacked on a penalty of $1,711 (20 percent of the deficiency, the IRS apparently having rounded off $1710.60 to $1711).
The basis of the deficiency was the taxpayers' failure to include in their taxable income for that year income realized by Mr...
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