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  5. 132 T.C. No. 4
 

SAMUELI v. COMMISSIONER OF INTERNAL REVENUE

Nos. 13953-06, 14147-06

132 T.C. No. 4

HENRY AND SUSAN F. SAMUELI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. THOMAS G. AND PATRICIA W. RICKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 16, 2009.

Attorney(s) appearing for the Case

Nancy L. Iredale, Jeffrey G. Varga, and Stephen J. Turanchik, for petitioners.

Miles B. Fuller and Louis B. Jack, for respondent.

OPINION

KROUPA, Judge.

These consolidated cases are before the Court on petitioners' motion for summary judgment and respondent's cross-motion for partial summary judgment. Respondent determined a $2,177,532 deficiency for 2001 and a $171,026 deficiency for 2003 in the Federal income taxes of Henry and Susan F. Samueli (collectively, Samuelis). Respondent determined a $6,126 deficiency for 2001 in the Federal income tax of Thomas G. and Patricia W. Ricks...

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