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PASCHALL v. COMMISSIONER

Docket Nos. 10478-08, 25825-08.

137 T.C. 8 (2011)

ROBERT K. AND JOAN L. PASCHALL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 5, 2011.

Attorney(s) appearing for the Case

Howard S. Fisher , for petitioners.

Ronald S. Collins, Jr. , John A. Guarnieri , and Cindy Park, for respondent.

WHERRY, Judge:

These consolidated cases are before the Court on petitions for redetermination of respondent's determinations, in notices of deficiency, that petitioners owe excise tax deficiencies and section 6651(a)(1) additions to tax for their 2002 through 2006 tax years as well as an income tax deficiency and a section 6662(a) accuracy-related penalty for their 2005 tax year.2

The issues for decision are: (1) Whether petitioner...

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