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GARNETT v. COMMISSIONER OF INTERNAL REVENUE

No. 9898-06.

132 T.C. No. 19

PAUL D. GARNETT AND ALICIA GARNETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 30, 2009.

Attorney(s) appearing for the Case

Jeffrey D. Toberer and Donald P. Dworak, for petitioners.*

J. Anthony Hoefer, for respondent.

OPINION

THORNTON, Judge.

This case is before us on the parties' cross-motions for partial summary judgment. Respondent determined the following deficiencies in and penalties on petitioners' Federal income taxes:

Penalty Year Deficiency Sec. 6662(a) ...

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