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BERGMANN v. COMMISSIONER

Docket No. 20894-05.

137 T.C. 136 (2011)

JEFFREY K. AND KRISTINE K. BERGMANN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 11, 2011.

Attorney(s) appearing for the Case

Ronald B. Schrotenboer , Kenneth B. Clark , and Brad A. Bauer , for petitioners.

Gerald A. Thorpe , for respondent.

KROUPA, Judge:

Respondent determined deficiencies in and accuracy-related penalties under section 6662(a)1 for petitioners' Federal income taxes for 2001 and 2002. Respondent has since conceded that petitioners are not liable for the 2001 and 2002 deficiencies in tax and the 2002 accuracy-related penalty. Petitioners concede they had a tax underpayment for 2001 if they failed to file a qualified amended return (QAR) under section...

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