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ROGERS v. COMMISSIONER OF INTERNAL REVENUE

No. 22667-07.

T.C. Memo. 2011-277

JOHN E. AND FRANCES L. ROGERS, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 23, 2011.

Attorney(s) appearing for the Case

Paul J. Kozacky and Nicholas C. Mowbray , for petitioners.

Laurie A. Nasky , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge.

Respondent determined a deficiency in petitioners' Federal income tax of $1,302,102 and an accuracy-related penalty under section 6662(a) of $260,420 for 2003.1

After stipulations2 the issues remaining for decision are: (1) Whether Portfolio Properties, Inc. (PPI), an S corporation incorporated under the laws of Illinois, must include...

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