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BROZ v. COMMISSIONER

Docket No. 21629-06.

137 T.C. 46 (2011)

ROBERT AND KIMBERLY BROZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 1, 2011.

Attorney(s) appearing for the Case

Stephen M. Feldman and Eric T. Weiss , for petitioners.

Meso T. Hammoud , Elizabeth Rebecca Edberg , and Steven G. Cappellino , for respondent.

KROUPA, Judge:

Respondent determined over $16 million of deficiencies1 in petitioners' Federal income tax for 1996, 1998, 1999, 2000 and 2001 (years at issue). Respondent also determined that petitioners were liable for accuracy-related penalties of $563,042 for 1998, $386,489 for 1999, and $591,213 for 2000.

After concessions,2 we are asked to decide several issues, many of which present questions...

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