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RAMIG v. COMMISSIONER OF INTERNAL REVENUE

No. 29149-08.

T.C. Memo. 2011-147

JOHN C. AND MARGARET T. RAMIG, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 27, 2011.

Attorney(s) appearing for the Case

Kevin O'Connell and Katherine de la Forest (specially recognized), for petitioners.

John D. Davis and Katherine Caballero, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MORRISON, Judge.

On September 5, 2008, respondent (the "IRS") issued petitioners a notice of deficiency for tax years 2004 and 2005. The notice stated that the IRS (i) determined deficiencies in tax of $953 for 2004 and $22,1141 for 2005 and (ii) determined that the Ramigs were liable for penalties under section 6662(a)2 of $190.60 for 2004 and $4,442.80 for...

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